Treasury Announces First Outbound‑Investment Security Program Penalty

The U.S. Treasury’s first publicly announced civil penalty under the Outbound Investment Security Program (OISP) signals a shift toward aggressive enforcement of U.S. outbound investment controls. Amidi LLC was cited for not submitting a required 30‑day notification for its Chinese subsidiary’s roughly US$92,000 stake in a firm that develops embodied AI technology—a transaction that would not have been prohibited under the program. The penalty—more than twice the transaction value—illustrates the Treasury’s willingness to sanction only the notification failure, not the investment itself, and demonstrates its enforcement framework’s reliance on compliance record, intent, and remedial actions. The action also occurs just months after Congress enacted the Comprehensive Outbound Investment National Security Act of 2025 (COINS), which broadens the OISP’s scope and empowers Treasury to establish a non‑notified‑transaction identification program. Firms with foreign subsidiaries or controlled investment funds should audit their notification processes, ensure real‑time visibility into overseas transactions, and review screening and training procedures. Failing to meet the 30‑day deadline opens firms to a higher penalty and signals that the Treasury will push compliance even as new regulations are still being drafted, creating potential industry‑wide adjustments before mid‑2027 implementation.