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ARTICLE · 14 JANUARY 2026

U.S. Law Will Widen Constraints On Outbound Investments

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The Comprehensive Outbound Investment National Security Act of 2025 (the COINS Act), incorporated within the annual U.S. national defense legislation enacted on December 18, 2025...

GlobalGovernment, Public Sector
Christopher Caparelli
Christopher Caparelli
Aaron Hunt
Aaron Hunt
Amy Johnson-Spina
Amy Johnson-Spina
Michele Clarkin (Cousens)
Michele Clarkin (Cousens)
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The Comprehensive Outbound Investment National Security Act of 2025 (the COINS Act)1, incorporated within the annual U.S. national defense legislation enacted on December 18, 2025, puts into law an outbound investment security program that eventually will supersede and expand upon existing outbound investment rules implemented by the U.S. Treasury Department in January 2025.

What you need to know

  • U.S. outbound investment restrictions, previously adopted pursuant to an Executive Order of former President Biden, are now formalized into U.S. federal law, but new regulations may not be effective until March 2027.
  • In addition to China, Hong Kong, and Macau, the COINS Act defines a "country of concern" to include Russia, Cuba, Iran, North Korea, and Venezuela, the latter "under the regime of Nicolas Maduro".

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