美国行使长臂管辖、针对中国海外投资的制裁仅限于有形资产吗？本文基于美国对中国海外投资制裁的数据，重新审视了这一现实命题，来考察美国制裁的最新发展动向。研究发现，早在2018年，美国就开始关注并加紧制裁中国数字投资项目。究其原因，一方面，海外数字投资（特别是加密数字资产投资）可以绕过国际资金清算系统、规避制裁，这引起了美国的高度警觉；另一方面，海外数字投资与高新技术、网络基础设施等敏感信息密切相关，这难免不触发美国泛国家安全审查的敏感神经，成为列入包括禁止投资在内的各类制裁清单的重要诱因。进一步研究发现，中国企业针对此类制裁寻求救济的道路尚很艰辛，基于企业自身维权的认知，它们更倾向于选择美国国内法院而忽视相对公正的多边争端解决机制，由此导致维权多以失败告终。不过，事后救济毕竟属于“亡羊补牢”，如果企业能够重视投资争端预防、选择“境内关外”地区（诸如美国对外贸易区）投资，或许可以防患于未然。

Does the United States exercise long-arm jurisdiction and impose sanctions on China's overseas investment only on those tangible assets? Based on the data of the United States' sanctions on China's overseas investment, this article re-examines this realistic proposition to examine the latest developments of US sanctions. The study found that, as early as 2018, the United States began to pay attention to and intensify the implementation of such sanctions against China's digital investment projects. The analysis of the reasons shows that, on the one hand, overseas digital investment (especially crypto digital asset investment) can bypass the international funds clearing system and evade sanctions, which has aroused the United States' high vigilance. On the other hand, overseas digital investment is closely related to sensitive information such as high-tech and network infrastructure, which inevitably triggers the sensitive nerves of the United States' pan-national security review and becomes an important incentive for inclusion in various sanction lists including investment bans. Further research found that the road for Chinese companies to seek relief against such sanctions is still difficult. Based on the company's own understanding of rights protection, they are more inclined to choose US domestic courts rather than relatively fair multilateral investment dispute settlement mechanisms, which leads to the failure of rights protection. However, ex post relief is after all "better late than never". If companies attach importance to the prevention of investment disputes, and choose to invest in areas "within the borders but outside the customs" (such as US foreign trade zones), it mayprevent risks before they happen.