Treasury Imposes First Penalty Under Outbound Investment Security Program
On Oct. 7 the Treasury fined Amidi, LLC $200,000 for failing to notify on a covered transaction.
The Department of the Treasury’s Outbound Investment Security Program (OISP) requires U.S. persons to report certain transactions in foreign investment securities. On Oct. 7, 2026, it imposed its first civil penalty—$200,000—to investment firm Amidi, LLC for not filing the required notice of a covered transaction. The enforcement marks a clear signal that the Treasury is actively policing this program, raising the stakes for U.S. investment managers and financial advisors who facilitate cross‑border securities placements. The penalty also clarifies the scope of transactions subject to the OISP, which includes shares, debt, and structured products tied to non‑U.S. issuers when the underlying assets are in the U.S. Firms must evaluate whether their clients’ foreign investments fall under the program and ensure that proper notification, documentation, and reporting protocols are in place. Close monitoring of Treasury guidance, potential updates to the OISP’s filing thresholds, and proactive client compliance workshops will be essential to avoid future fines and reputational harm.