Saudi Arabia, the UAE, and the American Attention Stack: A Documented Pattern | Horizon Accord
The Attention Stack
Foreign sovereign wealth and the acquisition of American digital infrastructure
Over the past five years, a coordinated pattern of acquisition has transferred significant ownership of American digital infrastructure to foreign sovereign wealth entities, primarily from Saudi Arabia and the United Arab Emirates. The transactions have proceeded largely through legitimate financial channels, often with the direct involvement of individuals holding concurrent roles in United States foreign policy.
The cumulative effect is that foreign governments with documented records of digital surveillance, suppression of dissent, and strategic non-alignment with Western democratic norms now hold meaningful ownership positions in the platforms and systems that shape the information environment, behavioral data profiles, and artificial intelligence capabilities of the American public.
This analysis documents that pattern. It does not assert coordination or conspiracy. It asserts that the documented facts, taken together, warrant serious scrutiny by the appropriate oversight bodies before the remaining pending transactions close.
The Stack
To understand the significance of what has been acquired, it is necessary to understand the architecture of what this analysis calls the attention stack — the layered infrastructure through which digital platforms capture user attention, extract behavioral and financial data, and increasingly, shape the information environment through algorithmic recommendation and artificial intelligence.
| AI Layer | OpenAI · Anthropic · xAI — American frontier AI laboratories now holding UAE sovereign investment positions. The systems that will increasingly mediate how Americans access information, make decisions, and understand the world. |
| Social & Algo Layer | TikTok — algorithmic recommendation that does not merely show users what they want. It shapes what they want. |
| Major Publisher Layer | EA · Take-Two · Activision Blizzard — live service revenue models dependent on behavioral architecture with the added legitimacy of beloved brands |
| Mobile Gaming Layer | Scopely · Pokémon Go — behavioral manipulation, variable reward schedules, frictionless payment integration. Not selling entertainment. Monetizing compulsion. |
Foreign sovereign wealth entities now hold significant positions at every layer of this stack.
The Acquisitions: A Documented Pattern
In February 2021, Saudi Arabia's Public Investment Fund made initial investments of approximately one billion dollars in Electronic Arts, 1.4 billion dollars in Activision Blizzard, and acquired a 6.5 percent stake in Take-Two Interactive.① These were minority positions. They established PIF as a major insider stakeholder across the American gaming industry before any public discussion of the acquisitions' strategic implications had taken place.
In January 2022, PIF's gaming subsidiary Savvy Games Group — whose chairman is Crown Prince Mohammed bin Salman — acquired ESL and FACEIT, the two largest esports tournament organizations in the world, for a combined 1.5 billion dollars.② This gave Saudi Arabia direct operational control over the competitive infrastructure of global gaming.
In September 2022, Savvy Games Group announced a commitment of 37.8 billion dollars to gaming industry investment, with 13.3 billion dollars specifically earmarked for the acquisition of a major publisher.③ The announcement came at a moment when venture funding in gaming had declined by approximately 75 percent from its peak — giving PIF structural leverage over an industry experiencing capital stress.
In July 2023, Savvy completed the acquisition of Scopely for 4.9 billion dollars.④ Scopely's business model sits at the extractive end of mobile gaming — high-volume advertising spend, algorithmic engagement optimization, and revenue figures that significantly exceed what the entertainment value of the product would suggest. Scopely subsequently acquired Niantic's gaming division, including Pokémon Go, for 3.5 billion dollars in March 2025⑤ — adding one of the most behaviorally sophisticated location-aware platforms ever built to the Saudi sovereign portfolio.
On September 29, 2025, Electronic Arts announced it had entered into a definitive agreement to be acquired by a consortium comprising Saudi Arabia's Public Investment Fund, Silver Lake, and Affinity Partners for 55 billion dollars — the largest leveraged buyout in recorded financial history.⑥ The transaction increased Electronic Arts' debt from 2.2 billion dollars to 20 billion dollars. EA generates approximately 7.5 billion dollars in annual revenue, with 75 percent derived from live services — meaning recurring behavioral and payment data from hundreds of millions of active users.⑦ The transaction is pending regulatory approval and expected to close by June 2026.
The Consortium and Its Architecture
The EA acquisition is not simply a Saudi transaction. Its structure reveals a pattern of financial and political relationships that warrants examination as a system.
Silver Lake Partners, the private equity firm serving as co-acquirer, manages over 100 billion dollars in assets. Its limited partners include Saudi Arabia's Public Investment Fund and Abu Dhabi's Mubadala Investment Company. Mubadala additionally holds a direct minority ownership stake in Silver Lake itself.⑧ Gulf sovereign wealth is present in the EA acquisition not only as a named consortium member but as a capital source within the financial infrastructure of the deal's other named consortium member.
Affinity Partners, Jared Kushner's investment firm, was incorporated on January 21, 2021 — the day after Kushner left his role as Senior Adviser to President Donald Trump. Six months later, Saudi Arabia's Public Investment Fund committed two billion dollars to the firm as its primary institutional investor. Affinity Partners had no meaningful private equity track record at the time of this commitment.⑨
Reporting from the Center for Economic and Policy Research and Popular Information has indicated that PIF brought Affinity Partners into the EA acquisition deal over the objections of its own investment committee — specifically because Kushner's political relationships were expected to reduce regulatory friction with the Committee on Foreign Investment in the United States.⑩
That the individual in question simultaneously holds an informal advisory role in the current administration's foreign policy — including direct involvement in negotiations with the same Gulf states whose capital finances his firm — represents a conflict of interest that CFIUS's existing framework was not designed to address.
The UAE Dimension
Saudi Arabia is the most visible actor in this pattern. It is not the only one.
MGX is an Abu Dhabi-based investment firm established in March 2024 by two UAE sovereign entities: Mubadala Investment Company and the artificial intelligence firm G42. Its chairman is Sheikh Tahnoon bin Zayed Al Nahyan — the UAE's National Security Adviser and brother of UAE President Sheikh Mohammed bin Zayed.⑪ MGX is not a passive financial vehicle. It is the UAE's strategic instrument for acquiring positions in artificial intelligence infrastructure globally.
MGX's documented investment portfolio includes: a stake in the TikTok US joint venture alongside Silver Lake and Oracle; a position in OpenAI's 6.6 billion dollar funding round; a partnership role in the Stargate Project; investments in Databricks and xAI; and, as of February 12, 2026, a direct investment in Anthropic.⑫
The significance of the Anthropic investment should not be understated. Anthropic is one of the three primary frontier AI laboratories in the United States. Its systems are deployed across consumer, enterprise, and government contexts. MGX, an entity chaired by the UAE's national security chief, now holds a financial position in all three major American AI laboratories simultaneously.
The UAE has not aligned with Western sanctions against Russia following the 2022 invasion of Ukraine. Dubai has functioned as a primary corridor for Russian capital flight and sanctions circumvention since that time. Trade between Russia and the UAE increased substantially in the years following the invasion.⑬ This does not establish that MGX's investments serve Russian interests. It does establish that the entity now holding positions across American AI infrastructure maintains active financial and diplomatic relationships with a state in direct strategic conflict with the United States and its allies.
The Data Question
The combined portfolio described above represents something that has not previously existed: a coherent foreign sovereign ownership position spanning behavioral data collection at the gaming layer, algorithmic recommendation at the social media layer, and model development at the AI layer.
Electronic Arts' live service platforms collect continuous behavioral, financial, and social data from hundreds of millions of users across dozens of countries. This data includes payment information, social graphs, behavioral response patterns, and in many titles, voice and text communications. Saudi Arabia, through PIF, will upon transaction close be a primary owner of this data infrastructure.
TikTok's US joint venture, in which MGX holds a 15 percent managing stake alongside Silver Lake and Oracle, controls the algorithmic recommendation system used by more than 170 million American users. Critics including legal scholars and national security experts have raised concerns that the joint venture's structure does not fully satisfy the requirements of the divest-or-ban legislation passed by Congress and upheld by the Supreme Court, specifically regarding ByteDance's retained operational relationships with the US entity's commercial functions.⑭
Saudi Arabia's record in the domain of digital surveillance is extensively documented. The kingdom has used Pegasus spyware against journalists and dissidents, including in operations targeting individuals on American soil. It has prosecuted citizens for social media posts. The CIA has assessed with high confidence that Crown Prince Mohammed bin Salman approved the killing of Washington Post journalist Jamal Khashoggi.⑮ These are not historical footnotes. They represent the operational context within which Saudi sovereign capital is now acquiring American data infrastructure.
The Vision 2030 Framing and Its Limits
Saudi Arabia's gaming and technology acquisitions are consistently presented, by Saudi officials and sympathetic analysts, as components of Vision 2030 — the Crown Prince's program to diversify the Saudi economy away from oil dependency. This framing deserves scrutiny.
Genuine economic diversification would involve building domestic productive capacity — Saudi studios, Saudi developers, Saudi intellectual property. The acquisition pattern documented here does not do that. It acquires the revenue streams, data assets, and behavioral infrastructure of already-established foreign companies. Saudi Arabia is not building a gaming industry. It is buying the toll roads of someone else's.
The revenue generated by EA's live services, Scopely's mobile platforms, and the esports infrastructure of ESL and FACEIT does not build a Saudi economy. It flows to PIF. PIF is the investment instrument of the Saudi state. The distinction between sovereign revenue and economic development is not semantic. It is the difference between a nation building productive capacity and a government acquiring extraction infrastructure in foreign markets.
Questions for the Record
The following questions are submitted for the consideration of the relevant Senate committees in connection with their oversight of CFIUS and foreign investment in critical technology infrastructure. The pattern documented here cannot be adequately evaluated through individual transaction review. It requires sustained institutional attention to the cumulative picture.
The question before the Senate is not whether any single acquisition is harmful. It is whether the accumulation of these positions, by these entities, through these financial relationships, at this moment in the development of artificial intelligence and digital infrastructure, is consistent with the national interest — and whether the regulatory frameworks currently in place are adequate to evaluate that question.
That determination belongs to the Senate. This analysis exists to ensure it is made with full knowledge of the documented facts.
