China and Russia are already positioning themselves to profit from Ukraine’s nearly $588 billion reconstruction effort. As the Trump administration renews its focus on Russia-Ukraine peace talks, Congress must ensure that U.S. adversaries are shut out of Ukraine’s reconstruction. Treasury Secretary Scott Bessent pledged that no financier of Russia’s war machine would benefit from Ukraine’s reconstruction. Yet one year later, the reconstruction fund established by the U.S.-Ukraine Critical Minerals Agreement still lacks an enforcement mechanism to uphold the Secretary’s commitment.
Congress now has a vehicle to act. Rep. Joe Wilson’s (R-SC) bipartisan Amendment 377 to the FY 2027 National Defense Authorization Act (NDAA) would direct the Pentagon’s Office of Strategic Capital to assist Ukraine in developing a screening mechanism for the fund. This measure would protect the U.S.-Ukraine Reconstruction Investment Fund from Moscow and those countries that have helped fuel its war.
This Policy Alert outlines how China and Russia seek to profit from Ukraine’s reconstruction, what’s at stake if they succeed, and what Congress can do.
FDD Action Expert Analysis
“The United States signed the Critical Minerals Agreement to secure strategic assets for America. Chinese and Russian involvement would directly undermine that strategy: Beijing invests and builds infrastructure to create dependencies it can exploit for coercion, and Russia uses a similar strategy, seeking to achieve through capital what it cannot achieve by force. Implementing a screening mechanism is critical to guarantee the agreement’s effectiveness. Amendment 377 enables Congress to ensure the minerals agreement benefits the United States, instead of benefiting our adversaries who have profited off Russia’s invasion.”
– Daniel Vaynshteyn, Associate Director of Government Relations, FDD Action
What’s at Stake
Beijing is seeking involvement in Ukraine’s rebuilding, while Moscow’s sanctions-evasion network is prepared to shift to legitimate investment once a ceasefire is in place.
- Beijing’s motives in Ukraine: Beijing’s rejected 2025 proposal to end the war in Ukraine was especially revealing. The plan would have seen a U.S.-Russia summit without Ukrainian and European leaders while promoting Chinese participation in post-conflict reconstruction. If Beijing had succeeded, it would have driven a wedge in the transatlantic alliance and cut Kyiv out of negotiations while profiting off rebuilding the country ravaged by its partners in Moscow.
- China plays for leverage: Chinese Leader Xi Jinping’s peace-broker play is ultimately about improving China’s image and relations with Washington. However, Xi’s refusal to end aid to Russia’s war effort indicates his desire to maintain leverage over Moscow. Xi is playing the same game in Kyiv by seeking a foothold in Ukraine’s reconstruction.
- Accomplice to war: In August 2024, the U.S. Commerce Department sanctioned 39 Chinese companies for funneling semiconductors and other sensitive electronics to Russia’s military. Moreover, Ukrainian intelligence confirmed that China has supplied key products to at least 20 Russian defense plants and that 80% of the “critical electronics” used in Russian drones came from China as of early 2025.
- Russia’s sanctions evasion network: Russia’s wartime economy has been sustained by a system of banks, shell companies, and intermediaries operating through China, Turkey, and Central Asia. That same network could be repurposed to launder Russian capital into Ukraine’s reconstruction once a ceasefire opens investment channels.
With hundreds of billions of dollars on the line, the stakes of not implementing a screening mechanism are too large to ignore.
- Billions in play: The World Bank, United Nations, and European Commission estimated that the total cost of Ukraine’s reconstruction and recovery could reach $588 billion over the next decade.
- Capital already flowing in: The U.S.-Ukraine Reconstruction Investment Fund portal for project proposals is live and has already drawn 282 applications and approved its first investment. Given the administration’s goal to have the private sector lead investment in Ukraine’s recovery and post-conflict economy, policymakers should act quickly to establish a screening framework and safeguards against adversaries’ involvement.
- Risk of hostile investment: If adversarial capital flows into Ukraine before a screening architecture exists, it could undermine the U.S.-Ukraine fund and create adversarial economic dependencies that the United States wants to avoid in Ukraine and other partner countries.
What Policymakers Can Do
The administration should work with Ukraine to create an investment screening mechanism under the critical minerals agreement.
- The Treasury Department should assist Ukraine with setting up a screening mechanism based on Secretary Bessent’s pledge that “no state or person who financed or supplied the Russian war machine will be allowed to benefit from the reconstruction of Ukraine.”
- Congressman Joe Wilson’s amendment demonstrates that they can utilize Congress as a serious partner in these efforts.
Congress should adapt Rep. Wilson’s Amendment 377 to the FY 2027 NDAA into standalone legislation.
- Congress should introduce this amendment as standalone legislation. This bill would send a clear signal and help the administration fulfill the intent of the minerals agreement.
Expand the screening mechanism to include sectors beyond critical minerals.
- Extend the screening framework beyond critical minerals to include Ukraine’s defense industrial base and other critical sectors, such as telecommunications, agriculture, and critical infrastructure.
- If the administration works with Ukraine to expand the scope of the mechanism, Congress should codify this work.
About FDD Action
FDD Action is a 501(c)(4) advocacy organization that works directly with policymakers to advocate for a robust U.S. foreign policy — one that strengthens U.S. national security, does damage to America’s adversaries, and supports allies and partners. FDD Action serves as a trusted resource for congressional offices and executive branch policymakers navigating complex national security challenges, leveraging a team with decades of experience on Capitol Hill and in the policy arena.