Wilson Sonsini Goodrich & Rosati·FINANCIAL REGULATION

Treasury Expands Outbound Investment Security Program Under COINS Act

The Treasury's new rule broadens the Outbound Investment Security Program, potentially reshaping how U.S. companies invest abroad in high-growth sectors like biotech and AI.

Treasury’s Proposed Rule, issued October 22, 2026, replaces and expands its current Outbound Investment Security Program (OISP) under the COINS Act. The new framework extends mandatory reporting and eligibility to a wider array of asset classes, including biotech, AI, and other high-growth sectors, and adds tighter oversight of outbound investments that may be seen as a threat to U.S. national security or foreign policy objectives. For clients, the rule imposes new filing requirements, heightened due-diligence standards, and increased scrutiny of held foreign securities, with an effective date slated for the fiscal year after the rule’s finalization. Compliance teams must review the proposed thresholds, gather updated foreign-investment data, and coordinate with tax, litigation, and risk groups to mitigate potential liabilities or sanctions exposure. The Treasury’s move is expected to prompt closer monitoring of cross-border deals, change the risk profile of certain M&A targets, and influence how firms structure international equity and debt holdings.

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Read the original firm alert → Friday, October 30, 2026

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