On October 7, 2026, U.S. Department of the Treasury (“Treasury”) announced that it imposed its first civil penalty of $200,000 against U.S. company Amidi LLC (“Amidi”) under the Outbound Investment Security Program (“OISP”). The OISP came into effect on January 2, 2025, requiring that U.S. persons notify Treasury of certain types of investments, whether made directly or through their controlled foreign entities, into entities of designated “countries of concern” engaged in or connected to the designated sensitive sectors of quantum computing, artificial intelligence, and semiconductors (see Update of November 13, 2024).

On April 19, 2025, Amidi’s Chinese subsidiary invested approximately $92,478 in a private Chinese company that develops artificial intelligence, robotics, and embodied intelligence. Treasury said it discovered the transaction “as part of its regular and ongoing compliance and market monitoring efforts” and that the penalty was imposed in July 2026. Treasury stated that Amidi violated rules that require U.S. companies to: (1) notify Treasury about any transaction by a foreign subsidiary that would normally need to be notified if that same transaction were carried out by a U.S. company, and (2) take all reasonable steps to prevent such a transaction.

The jurisdiction of the OISP is set to expand following the passage of the Comprehensive Outbound Investment National Security Act of 2025 (“COINS Act”) on December 18, 2025. However, the COINS Act will not take effect until Treasury completes its implementing regulations, which must be completed no later than 450 days after the passage of the COINS Act (i.e., March 13, 2027).

Among other things, the expanded jurisdiction of OISP will include additional countries and technology sectors. In addition to the existing “countries of concern” – China, Hong Kong, and Macau – the COINS Act covers Cuba, Iran, North Korea, Russia, and Venezuela under the Maduro regime. In addition to the existing sensitive technologies, it adds hypersonic systems, high‑performance computing, and supercomputing.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

David Chieng**

David is a law clerk in the International Trade practice group; he is not admitted to the practice of law.