Yes. Loans and investments may count toward SSBCI requirements if they are from a private source as described in Section VIII.b of the Guidelines, even if that source originates outside of the United States. In accordance with Presidential Memorandum dated February 21, 2025, it is the policy of the United States to preserve an open investment environment and Treasury encourages investments that will magnify federal SSBCI funding and support American small businesses. 

The transaction, including the use of the private financing, must otherwise comply with all SSBCI requirements and any other applicable state, local, or federal law, including Committee on Foreign Investment in the United States (CFIUS) filing requirements that may be triggered (see, 31 CFR Parts 800 and 802). Participating jurisdictions should be mindful of these requirements and should communicate the same to their participating providers. In particular, while investment from a foreign sovereign wealth fund will qualify as private financing for purposes of SSBCI requirements (i.e., it does not originate from a domestic public source such as a state, federal, or Tribal government), such investments may be within CFIUS jurisdiction for purposes of CFIUS review. Treasury encourages participating jurisdictions to notify Treasury if they are engaging with foreign sovereign wealth funds; for example, foreign sovereign wealth fund participation in a venture capital fund may be relevant information to include in a notification under FAQ #13 in Section VIII.i.