Corpus v4· 4,812 policies· 28 jurisdictions· Last revision 22 Aug 2026: Affiliates Rule reimposed

Arqis/Solutions/Sovereign & institutional investors

Every stake is a position, not a moment.

A syndicate that clears CFIUS at closing can cross a mandatory-filing threshold a year later without a single new dollar changing hands. Arqis determines what CFIUS, outbound investment, export control and disclosure rules require for a stake, and keeps that answer live for as long as you hold the position.

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TA-2026-0703
Decided 21 Jul 2026 · corpus v1
Monitored
Conditional

Take a 12% stake and a board observer seat in a US AI infrastructure company, alongside a syndicate that includes a state-owned co-investor.

TID business classification31 CFR 800.401
Aggregate syndicate ownership31 CFR 800.212
Foreign government interest31 CFR 800.244
Governance rights review31 CFR 800.208
Reopened by corpus v4
  • Verdict Conditional → Restricted
  • Filing status Voluntary → Mandatory declaration
  • Co-investor's follow-on stake pushed aggregate foreign-government interest past 49%

The exposure

One position, six ways to be exposed.

A single stake can carry all of these at once: the deal structure, the technology it touches, and the syndicate you closed alongside.

Structuring31 CFR 800Voluntary vs mandatory CFIUS declaration triggers
Technology access15 CFR 744End-use screening for any technology the portfolio company licenses back
Outbound31 CFR 850Exposure where US-affiliated co-investors sit in the same syndicate
Governance31 CFR 800.208Board seats and observer rights read as control rights
Bulk dataEO 14117 · 28 CFR 202Portfolio company access to bulk sensitive personal data tied to the position
DisclosureReg S-K · Item 103Portfolio company disclosure obligations tied to the investment

Continuous monitoring

Positions move faster than the paperwork.

A stake is taken once. The syndicate around it, and the rights attached to it, keep changing for as long as you hold it.

First

The rule changes

A mandatory-declaration threshold shifts, a sector is added to the TID list, a previously voluntary filing becomes mandatory. Every position that cited the affected policy re-runs and reopens if it no longer clears.

Register

Second

The syndicate changes

A co-investor increases their stake, a board seat becomes a designated control right, aggregate foreign-government interest crosses 49%. The conditions your filing depends on become monitored controls.

Verify

We don't decide which stakes should clear.

Arqis determines what each applicable regime requires for the position in front of you. A US lead investor, a European pension fund, a Gulf sovereign co-investor and the portfolio company itself can all rely on the same determination.

Decide

Cited, position by position

Every test on a stake or a syndicate structure names the rule it applied, the effective date, and the confidence. The reasoning is exposed rather than asserted.

Verify

Syndicates become monitored positions

Aggregate ownership, governance rights and designation status are watched across every co-investor, not assumed static after closing.

Escalate

Arqis computes, counsel judges

A disputed filing status or a contested co-investor goes to your own counsel, carrying the full trace, so they start from our work rather than from zero.

Who it's for

Built for the teams who sign the term sheet.

Arqis sits wherever a cross-border stake has to be defended later, not just cleared at closing.

Investment committee & deal leads

Know before IC sees it

Screen a stake and its syndicate against every applicable regime before the term sheet is signed, not after a filing is challenged.

Legal & regulatory affairs

One file per syndicate, not per fund

Every filing decision cited to the rule that produced it, consolidated into a single record that stays current after close.

Portfolio & asset management

Watch positions after close

Ownership, governance rights and designation status monitored for the life of the holding, not just at the closing binder.

Government & LP relations

Answer the mandate question before it's asked

Show an LP, a regulator or a co-investor a position that is monitored, not a memo that was only ever true at signing.

Working session

Bring us one position you're unsure about.

Ninety minutes. We run it against every applicable regime on your own syndicate and show you the trace. No slides.

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Tell us roughly what the transaction involves

We reply within one business day. Or email team@arqis.ai directly.

See a determination