---
title: "U.S. Escalates Techno-Nationalist Campaign: Analyzing the 2025 Actions Against Tencent and Alibaba"
author: "DeepValues Research"
publisher: "DeepValues Research (DeepValues / LuLu Ventures LLC)"
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date: "2026-02-19"
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answer: "DeepValues Research, “U.S. Escalates Techno-Nationalist Campaign: Analyzing the 2025 Actions Against Tencent and Alibaba” (Feb 19, 2026): The U.S. government's actions against Chinese technology giants in 2025, specifically the Department of Defense (DoD) designation of Tencent in January and the White House allegations against Alibaba in November, are not isolated incidents."
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---
# U.S. Escalates Techno-Nationalist Campaign: Analyzing the 2025 Actions Against Tencent and Alibaba

**Date:** 18 November 2025

**Report By:** Geopolitical Risk Analyst, U.S.-China Technology and National Security Policy

**Report ID:** GR-USCN-2025-11-18

**Distribution:** Restricted. For Client Briefing Purposes Only.

## Executive Summary

The U.S. government's actions against Chinese technology giants in 2025, specifically the Department of Defense (DoD) designation of Tencent in January and the White House allegations against Alibaba in November, are not isolated incidents. They represent two distinct, complementary, and escalating tactics within a singular, whole-of-government U.S. strategy to counter China's national doctrine of Military-Civil Fusion (MCF).

The January action against Tencent was a formal, bureaucratic designation, placing the company on the "Section 1260H" list of "Chinese military companies". While this move had limited immediate legal impact, it triggered severe, delayed-action consequences for the entire U.S. defense supply chain, effectively mandating a long-term, structural decoupling from Tencent's ecosystem.

By contrast, the November action against Alibaba represents a significant escalation, shifting from bureaucratic process to direct political and information warfare. The leaking of a White House national security memo, citing declassified "top secret" intelligence that accuses Alibaba of actively helping the People's Liberation Army (PLA) target the U.S. with "zero-day" exploits, was designed to inflict maximum, immediate reputational and financial damage.

This analysis concludes that the U.S. government has effectively erased any operational distinction between "civilian" and "military" for major Chinese technology platforms. The deployment of both slow-acting, structural weapons (the 1260H list) and fast-acting, political weapons (memo leaks) creates a new, high-risk, and deeply uncertain operational and investment environment for any entity connected to the U.S.-China technology ecosystem.

## Part 1: The Alibaba Allegation (November 2025): A Shift to Information Warfare

The allegations that surfaced in November 2025 mark a significant change in U.S. tactics, moving from formal designations to direct, public accusations sourced from classified intelligence.

### 1.1. The White House National Security Memo

On or around November 14, 2025, media outlets, prominently the *Financial Times*, reported the existence of a White House national security memo accusing the e-commerce and cloud computing company Alibaba of providing direct technological support for Chinese military "operations" against U.S. targets.

The memo, reportedly dated November 1, 2025, was significant for its sourcing, which was cited as "newly declassified 'top secret' intelligence". The intentional declassification and subsequent leak of this intelligence-rather than a formal regulatory filing-suggests a primary goal of shaping the public narrative and inflicting immediate reputational damage.

The primary actor identified is the White House, operating under the Trump Administration. This elevates the accusation from a departmental (e.g., Commerce or Defense) compliance issue to one of executive-level national security policy, directly aligning with the administration's stated agenda of "Safeguarding American Innovation" from foreign adversaries.

### 1.2. Deconstructing the Allegations: From Data Access to "Zero-Day" Exploits

The claims detailed in the memo, as reported by media, are highly specific and escalatory, moving beyond general concerns about data privacy.

-   **Claim 1: Mass Data Provision:** The memo alleges that Alibaba provides the Chinese government and the People's Liberation Army (PLA) with access to its vast troves of customer data. This reportedly includes sensitive information such as user IP addresses, WiFi information, and payment records. This claim strikes at the core of Alibaba's business model, which relies on trust as a global e-commerce and cloud provider.

-   **Claim 2: Provision of AI Services:** The memo further claims that Alibaba supplies the PLA with various artificial intelligence-related services. This directly links the company to the U.S. government's primary national security fear: the "intelligentization" of the PLA, a key component of China's military modernization strategy.

-   **Claim 3: The "Zero-Day" Allegation:** The most severe and strategically significant accusation is that Alibaba employees transferred knowledge of "zero-day" exploits to the PLA. A zero-day is a software vulnerability that is unknown to the software vendor and, therefore, has no patch.

This third claim is a "smoking gun" allegation. It reframes Alibaba from a *passive* enabler of state surveillance-a company compelled by national security laws to share data-to an *active participant* in offensive PLA cyber-operations. This allegation equates elements of the company with state-sponsored hacking groups, such as the "RedNovember" or "Salt Typhoon" threat actors, which U.S. intelligence has linked to global cyber-espionage campaigns.

### 1.3. Immediate Impact and Corporate Response

The U.S. strategy of using an information-led attack proved effective in the short term.

-   **Financial Impact:** The report of the memo triggered an immediate and sharp market sell-off. Alibaba's (BABA) U.S.-listed shares dropped as much as 4.5% during trading on November 14, 2025, demonstrating the efficacy of the memo as an information weapon to inflict immediate financial pain.

-   **Corporate Response:** Alibaba issued a forceful and public denial. The company's response was notably political, not legal. An Alibaba spokesperson called the allegations "complete nonsense". The company further stated that the claims were "plainly an attempt to manipulate public opinion and malign Alibaba". This response indicates that Alibaba's leadership understood the memo not as a legal filing to be answered in court, but as a political attack to be countered in the press.

### 1.4. Contextual Pressure: The LA 2028 Olympics Controversy

The November 2025 memo was not an isolated event but rather the culmination of a year of escalating U.S. government pressure on Alibaba. The company was already in the crosshairs of U.S. policymakers.

In September 2025, the U.S. House Select Committee on the Chinese Communist Party (CCP) issued a public letter to the Secretary of Homeland Security. This letter detailed "serious national security concerns" regarding Alibaba's ongoing partnership with the International Olympic Committee (IOC) and its potential role in the 2028 Los Angeles Olympic Games.

The Select Committee's letter established a clear precedent, stating it *already* viewed Alibaba as a "direct enabler of the CCP's surveillance and intelligence apparatus" with "reported connections to Chinese military firms". The committee explicitly warned of "espionage, data exploitation, and foreign influence" risks should Alibaba be involved in critical infrastructure for the LA Games, such as cloud services, ticketing, or broadcasting.

The letter also cited the precedent from the Paris 2024 Olympics, where French cybersecurity officials had "actively worked to limit Alibaba's role" due to similar security concerns, ultimately ensuring that Olympic data remained within French jurisdiction. This pre-existing political campaign demonstrates that the White House's November memo was an escalation of a long-simmering conflict.

## Part 2: The Tencent Precedent (January 2025): The "Ancillary Impact" Weapon

The action against Alibaba in November was preceded by a more formal, bureaucratic action against its primary tech rival, Tencent, in January 2025. This earlier event provides the crucial context for understanding the U.S. government's multifaceted strategy.

### 2.1. The Designation: Addition to the "Section 1260H List"

On January 2, 2025, the U.S. Department of Defense (DoD) added Tencent Holdings, along with other prominent Chinese firms like CATL and COSCO Shipping, to its official list of "Chinese military companies" (CMCs).

This action was drafted and executed by the DoD, acting in accordance with a mandate from the U.S. Congress. The stated rationale for inclusion on the 1260H list is a company's alleged participation in China's "Military-Civil Fusion strategy". While the DoD did not provide a detailed public justification, the inference is clear: Tencent's "ubiquitous" role in Chinese society (via WeChat, WeChat Pay) and its advanced enterprise technologies (Tencent Cloud, VooV, security services) make it a critical "military-civil fusion contributor" whose assets the PLA "could use".

### 2.2. The Policy Tool: A Deep Dive into Section 1260H

Understanding the Tencent action requires a detailed analysis of the "Section 1260H" list, a nuanced and widely misunderstood policy tool.

-   **What it Is:** This is a list, mandated by Section 1260H of the 2021 National Defense Authorization Act (NDAA), requiring the DoD to identify entities it believes are "Chinese military companies".

-   **Definition of a CMC:** The law defines a CMC with two broad prongs. An entity qualifies if it is either (1) owned or controlled by, or acting on behalf of, the PLA, *or* (2) is a "military-civil fusion contributor to the Chinese defense industrial base". This second "dual-use" clause is the provision that allows the DoD to target nominally "private" and "civilian" companies like Tencent.

-   **What it is NOT (The Immediate Impact):** A 1260H designation is *not* a sanction in the traditional sense, such as a designation by the Treasury's Office of Foreign Assets Control (OFAC). By itself, the designation has limited and non-immediate legal consequences.

    -   It **does not** immediately ban U.S. persons or businesses from transacting with Tencent.

    -   It **does not** freeze Tencent's assets.

    -   It **does not** prohibit U.S. persons from investing in Tencent securities.

    -   It **does not** restrict the U.S. operations of Tencent's subsidiaries, such as gaming giant Riot Games (creator of *League of Legends*).

-   **The REAL Impact (The "Ancillary" Consequences):** The 1260H list's true power is not immediate but delayed and structural. It functions as a "trigger" for other, far more severe prohibitions embedded in subsequent U.S. law, which are designed to systematically purge designated entities from the U.S. defense-industrial base.

    1.  **DoD Procurement Ban:** Section 805 of the FY 2024 NDAA *prohibits the DoD* from procuring end products (effective June 30, 2026) and services (effective June 30, 2027) from any company on the 1260H list.

    2.  **Supply Chain Contagion:** This ban extends *indirectly* to all U.S. defense prime contractors (e.g., Lockheed Martin, Raytheon). These contractors are now required to conduct increased due diligence of their entire supply chain to ensure they are not indirectly procuring technology or components from Tencent.

    3.  **The "Lobbying" Ban (Political Isolation):** Section 851 of the FY 2025 NDAA prohibits the DoD (effective June 30, 2026) from entering into a contract with *any* U.S. company that *also* has a contract with a lobbying firm representing a 1260H entity. This is a powerful political isolation tool: it forces U.S. firms and Washington lobbyists to choose between their lucrative DoD contracts and their relationships with Tencent.

The 1260H list, therefore, functions as a "canary in the coal mine." Inclusion is a formal warning from the U.S. government that a company is "of concern" and that more severe, market-closing restrictions from other agencies (like OFAC or the Commerce Department's Bureau of Industry and Security) may be forthcoming.

### 2.3. Impact and Corporate Response

-   **Financial Impact:** The immediate effect of the January designation was primarily reputational, what one legal analysis called a "name and shame" list. It immediately added a new, significant layer of "compliance complexity" for any U.S. firm dealing with Tencent. This uncertainty was reflected in the market, with Tencent's Hong Kong-traded shares falling 7.3% on the news.

-   **Corporate Response:** In stark contrast to Alibaba's later political rebuttal, Tencent's response was procedural and legalistic. A spokesperson stated the inclusion was a "misunderstanding" or a "mistake". The company's official board filing confirmed this approach, stating it would "initiate a reconsideration process" with the DoD to "resolve any misunderstanding" and, if necessary, "undertake legal proceedings" to be removed from the list.

## Part 3: Comparative Analysis: A Tale of Two Strategies

When viewed together, the 2025 actions against Tencent and Alibaba reveal a sophisticated, multi-pronged U.S. strategy, not a series of ad-hoc attacks.

### 3.1. Key Table: U.S. Actions Against Alibaba and Tencent (2025)

| **Feature**                      | **Tencent Action (January 2025)**                                                                                                                                    | **Alibaba Action (November 2025)**                                                                                                                                    |
|----------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| **Primary U.S. Actor**           | **Department of Defense (DoD)**                                                                                                                                      | **The White House** (Trump Admin)                                                                                                                                     |
| **Formal Mechanism**             | **Bureaucratic Designation:** Addition to the "Section 1260H List"                                                                                                   | **Political/Information Operation:** Leak of a White House national security memo                                                                                     |
| **Legal/Policy Basis**           | **Congressional Mandate:** Section 1260H of the FY2021 NDAA                                                                                                          | **Executive Authority:** National security "Safeguarding American Innovation" mandate                                                                                 |
| **Core Allegation**              | **Passive/Potential Threat:** A "military-civil fusion contributor" whose tech (cloud, data) *could* be used by the PLA                                              | **Active/Hostile Threat:** *Actively* providing the PLA with data, AI, and "zero-day" exploits to *target the U.S.*                                                   |
| **Immediate Legal Consequence**  | **None.** No ban on business, investment, or operations.                                                                                                             | **None.** The memo itself carries no legal weight.                                                                                                                    |
| **Immediate "Real" Consequence** | **"Name & Shame":** Reputational damage, compliance complexity, stock dip                                                                                            | **"Shock & Awe":** Severe reputational damage, market panic, stock sell-off                                                                                           |
| **Future/Ancillary Consequence** | **Extremely Severe & Delayed:** Binds the *entire* U.S. defense sector. Prohibits DoD procurement (2026/2027) and contracts with firms that lobby for Tencent (2026) | **Ominous Precursor:** Signals that formal, severe sanctions (e.g., Entity List, OFAC) are likely, as the U.S. has already publicly declared Alibaba a hostile actor. |
| **Corporate Response**           | **Procedural/Legal:** "A mistake." Will "initiate a reconsideration process" and "legal measures"                                                                    | **Political:** "Complete nonsense." An "attempt to manipulate public opinion"                                                                                         |

### 3.2. Analysis of Comparative Strategies

The comparison demonstrates that the U.S. government used two different tools for two different purposes. The 1260H list (used on Tencent) is a *structural* weapon. It is a slow, bureaucratic, and legalistic "boa constrictor" designed to methodically *decouple* the U.S. defense supply chain from a target over a multi-year period. Its power is in its delayed, irreversible, and systemic impact.

The memo leak (used on Alibaba) is a *shock* weapon. It is a fast, political, and media-driven "viper strike" designed to inflict immediate *punishment*, shape the global narrative, and create political justification for future formal actions. The U.S. is demonstrating it can and will use both tactics to achieve its strategic objectives.

## Part 4: The Strategic Framework: China's Military-Civil Fusion (MCF) and the U.S. "Whole-of-Government" Response

Both the Tencent and Alibaba actions are a direct response to a single, core strategic concern in Washington: China's national strategy of Military-Civil Fusion (MCF).

### 4.1. The "Why": China's National Strategy of Military-Civil Fusion (MCF)

Military-Civil Fusion is a "whole-of-society approach" directed by the Chinese Communist Party (CCP) to integrate civilian industries, universities, and research initiatives with its defense development. The goal is to rapidly modernize the PLA by systematically eliminating the barriers between China's civilian-commercial technology sector and its defense-industrial base.

This strategy explicitly targets "dual-use" technologies where civilian firms are the global leaders: Artificial Intelligence (AI), quantum computing, semiconductors, cloud computing, and biotechnology.

From the U.S. perspective, Alibaba and Tencent-as two of the "Seven Giants of the AI age" and the primary engines of China's AI and cloud development -are the *centerpieces* of the MCF strategy. U.S. policymakers view Chinese national plans, such as "Made in China 2025" and the "New Generation AI Development Plan" , as state-level directives that *compel* these firms to support the PLA's "intelligentization" of warfare. This perception makes the distinction between "civilian" and "military" technology in China meaningless to Washington.

### 4.2. The "Who": The Architects of the U.S. Whole-of-Government Response

The query's question of "who drafted them" points to a multi-layered, interlocking U.S. government apparatus, not a single actor.

-   **The White House:** Sets the national strategy. A February 2025 National Security Presidential Memorandum (NSPM) explicitly promised to "stop U.S. companies from pouring investments into China" that support MCF and to use the Committee on Foreign Investment in the United States (CFIUS) to restrict Chinese investment. The Alibaba memo is a direct execution of this executive-level strategy.

-   **The U.S. Congress:** Creates the legal tools and applies political pressure. Congress *created* the 1260H list in the 2021 NDAA, mandating that the DoD act. The House Select Committee on the CCP provides a continuous drumbeat of political pressure, as seen in its March 2025 "China Threat Snapshot" and the September 2025 letter regarding Alibaba and the LA Olympics.

-   **The Department of Defense (DoD):** Executes the military-facing mandates. The DoD drafts the 1260H list and provides the intellectual "ammunition" for the entire U.S. government through its annual *China Military Power Report* , which meticulously details the PLA's modernization and MCF strategy.

-   **The Department of Commerce (BIS):** Controls the technology chokepoints. The Bureau of Industry and Security manages the *Entity List*, a separate and more powerful tool that restricts access to U.S. technology (like AI chips).

-   **The Department of Homeland Security (DHS):** Manages supply chain access based on other factors, such as the Uyghur Forced Labor Prevention Act (UFLPA), demonstrating the *multiple* fronts on which Chinese companies are being vetted.

### 4.3. The Strategic Feedback Loop: How U.S. Policy Accelerates MCF

A critical, self-reinforcing feedback loop is at play. U.S. policies designed to counter MCF are, in practice, accelerating it.

The U.S. (via Commerce/BIS) has imposed strict export controls on high-performance AI chips (GPUs) to slow China's AI development. These sanctions have created tangible "supply chain constraints" for companies like Tencent. In 2025 earnings calls, Tencent executives admitted that while they have *current* GPU reserves, "supply chain constraints sourcing GPUs" are a "limiting factor" for their AI cloud business.

This U.S. pressure, combined with a slowing domestic economy , forced the Chinese government to "hit the reset button" on its own regulatory crackdown on its tech sector. In February 2025, President Xi Jinping convened a high-profile meeting with tech CEOs, including those from Alibaba, Tencent, and Huawei. He *explicitly* tasked them with enhancing national "technological innovation" to counter U.S. sanctions and achieve technological self-sufficiency.

The U.S. government observes this *deeper*, state-directed fusion-which its own policies prompted-as *proof* of the existential threat posed by MCF. This "proof" is then used to justify the next round of escalations, such as the 1260H designation of Tencent and the inflammatory memo targeting Alibaba.

## Part 5: Concluding Analysis and Forward Outlook

### 5.1. Combined Impact and Parallel Pressures

The actions against Alibaba and Tencent are one layer of a multi-layered assault. The most potent weapon in the U.S. arsenal remains the export control on advanced semiconductors. This is not a future threat but a present-day reality, already slowing the growth of Tencent's AI cloud division.

Furthermore, the White House has explicitly stated its goal is to "stop U.S. companies from pouring investments into China" and is considering new restrictions on U.S. outbound investment in sensitive Chinese technologies. This creates a "chilling effect" on capital, starving these firms of foreign investment and U.S. market access.

### 5.2. Forward Outlook and Future Scenarios

The events of 2025 have established a new, more aggressive baseline for U.S. policy. The following scenarios are now highly probable:

-   **Scenario 1 (Likely): Alibaba is Formalized.** The November memo was the political justification. The next logical step is a *formal* designation. Alibaba is now at extremely high risk of being added to the DoD's 1260H list (like Tencent) or, more severely, being added directly to the Commerce Department's *Entity List*. The "zero-day" exploit allegation provides a powerful justification for an Entity List designation, which would restrict Alibaba's access to U.S. technology.

-   **Scenario 2 (Likely): Tencent is Escalated.** Tencent is currently appealing its 1260H designation. If this appeal fails, or if U.S.-China relations deteriorate further, the U.S. government may "graduate" Tencent from the 1260H list to a more restrictive one, such as the Entity List or the Treasury's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which would restrict U.S. investment.

-   **Scenario 3 (High Likelihood): The Net Widens.** The U.S. has now successfully established and executed a "playbook" for targeting China's largest tech firms-using a bureaucratic tool for Tencent and a political one for Alibaba. Other major Chinese tech firms with "dual-use" applications-such as Baidu (AI, autonomous driving), ByteDance (AI, data), and leading "hard tech" firms in robotics and quantum -are now squarely in the U.S. government's crosshairs.

The core conclusion is unavoidable: The U.S. distinction between civilian and military technology in China is, for all practical purposes, dead.

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