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ARTICLE · 03 NOVEMBER 2026

Treasury Proposes Expanded Outbound Investment Restrictions Under The COINS Act

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The U.S. Treasury Department has proposed sweeping changes to outbound investment restrictions that would dramatically expand prohibitions on AI and biotechnology investments in countries of concern. The new rules would eliminate distinctions for AI systems based on training compute, potentially affecting commercial technology developers, and introduce comprehensive biotechnology restrictions covering pharmaceutical development and research platforms. These proposed regulations mark a substantial broadening

GlobalGovernment, Public Sector
Christopher Forsgren
Christopher Forsgren
Brian J. Fleming
Brian J. Fleming
Evan Abrams
Evan Abrams

On October 22, 2026, the U.S. Department of the Treasury issued a notice of proposed rulemaking (NPRM) to implement Subtitle C of the Comprehensive Outbound Investment National Security Act (COINS Act). As discussed in our prior post, the Act codifies and expands the Outbound Investment Security Program (OISP), which currently restricts certain U.S. person investments involving entities linked to China. Among other key changes, the proposal would substantially broaden restrictions on investments involving artificial intelligence (AI) and add biotechnology, potentially affecting a wide range of commercial technology and life sciences businesses. Comments on the proposed rule are due December 7, 2026.

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