Treasury Proposes COINS Act Rule Adding Biotech, Banning Super Intelligence Investments

Mayer Brown reports that the U.S. Treasury has released a proposed rule to implement the COINS Act, broadening existing outbound investment restrictions in two notable ways: adding biotechnology to the covered sectors and prohibiting investments in "super intelligence." For clients in venture capital, corporate development, and strategic investing, the practical effect is to expand the universe of transactions requiring screening before closing and to push compliance work earlier in the deal timeline, since covered investments would generally need to be identified and structured at term-sheet stage rather than at notice or closing. Biotechnology and frontier AI investors should revisit investor and diligence questionnaires, joint venture and minority-stake structures, and board-level risk protocols given an anticipated widening of covered technology categories. Corporate development teams should reassess pending and contemplated transactions with non-U.S. co-investors and offshore holding structures. Counsel should watch the comment process and the final rule's definitions of covered technology, covered countries and jurisdictions, and covered investor status. The available summary does not confirm effective dates, monetary or technology thresholds, or the comment deadline; those details should be verified against the Treasury publication and Federal Register notice directly before acting.