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On 25 June 2026, the UK Government published its decision to block the acquisition of TTG Global Solutions Group Limited (TTG Global) by Shenzhen HYT Science & Technology Co., Ltd (Shenzhen HYT) on national security grounds (Acquisition of TTG Global Solutions Group Limited by Shenzhen HYT Science & Technology Co., Ltd - GOV.UK).
TTG Global is a UK-based, global provider of critical communications solutions. It provides mission-critical communication infrastructure to emergency services, airports and energy providers including both systems integration services designed to ensure seamless and secure communications across networks and robust vehicle communication and location devices. Shenzhen HYT is part of Hytera, a China-based provider of wireless communication terminals, services and systems. While publicly listed on the Shenzhen stock exchange, it is partly state-owned (as a result of investment by the Shenzhen Investment Holdings) and has previously been the subject of national security concerns in other jurisdictions (including the US).
Whilst the UK does indicate when final orders have been issued in national security cases, the details provided publicly are extremely brief. In this case, the published information states that the prohibition is necessary and proportionate to prevent risks to national security relating to:
“i. TTG Global Solutions Group Limited’s role as a critical supplier of products and services to UK critical national infrastructure, government and emergency services, the disruption or compromise of which could cause harm to UK national security; and
ii. sensitive data held by or accessible to TTG Global Solutions Group Limited, access to which could cause harm to UK national security.”
The case is noteworthy because it is the first transaction to be blocked by the UK this year and only the fifth since the regime came into force in January 2022. The vast majority of transactions that are reviewed under the UK National Security & Investment (NS&I) Act are cleared unconditionally with a handful each year being cleared subject to conditions (17 out of the 1,079 transactions reviewed in the most recent FY24/25 reporting period). However, there is a noticeable trend: all five transactions that have been prohibited under the regime have involved Chinese or Hong Kong acquirers. Similarly, two of the three final orders requiring divestments have related to Chinese acquirers (the third related to a company owned by individuals linked to Russia who were subject to sanctions).
Looking at the wider picture, it is clear that the nationality of the acquirer is not the only factor that the UK Government considers in determining which cases should be called-in for an in-depth review or for which final orders are made. Indeed, the NS&I Annual Report for the FY24/25 period notes that almost half (48%) of the 56 transactions called-in for an in-depth review and 11 out of 17 final orders were made in relation to acquisitions involving UK-associated acquirers. However, although the figure was lower than in previous reporting periods, acquirers associated with China nonetheless made up about one third (32%) of the transactions called-in for an in-depth review.
The UK Government has repeatedly stated that inward investment is welcomed and factors other than an acquirer’s nationality or those of its ownership play a key role in the multi-factorial national security risk assessment undertaken by the UK Government. Indeed, in our experience, even acquisitions by investors from jurisdictions more likely to come under particular scrutiny can nonetheless still obtain (un)conditional NS&I Act clearance.
However, achieving such outcomes will turn on the other key factors – e.g., sector in which the target is active/the nature of its activities and the level of control to be acquired. While the UK Government’s decision does not provide details as to how it balanced these factors when undertaking its assessment of the transaction, the level of control being acquired (100%) and the potential sensitivity of the target’s activities (given the likely UK end-customers and use-cases for its products and services) are likely to have been of importance.
The UK Government’s decision emphasises the continuing importance of undertaking a sufficiently robust assessment of NS&I aspects of transactions involving UK entities active in sensitive sectors (particularly where acquirers are linked to jurisdictions which have come under particular scrutiny). It also particularly underlines the risk that, in a small number of cases, the UK Government may not be persuaded that the extensive ‘toolbox’ of remedies it has at its disposal can meet the national security concerns it has identified.
There has been a clear trend of heightened activity in this area in regimes across the world. This trend is expected to continue, with FDI regimes continuing to be strengthened. For example, the EU published in the Official Journal on 26 June 2026 its new Regulation on the screening of foreign investments. This requires all Member States to have screening mechanisms in place for certain mandatory sectors and for a more formal cooperation mechanism between Member States by early 2027 (Regulation (EU) 2026/1386 of the European Parliament and of the Council of 17 June 2026 on the screening of foreign investments in the Union and repealing Regulation (EU) 2019/452).
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