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ARTICLE · 21 OCTOBER 2026

Treasury Announces First Civil Penalty Under Outbound Investment Security Program

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The U.S. Treasury Department has issued its first civil penalty under the Outbound Investment Security Program, fining a company $200,000 for failing to notify authorities about an investment in a Chinese AI firm. This enforcement action reveals Treasury's proactive monitoring capabilities and signals the serious consequences investors face for non-compliance with notification requirements, even for relatively small transactions.

United StatesGovernment, Public Sector
Evan T. Abrams
Evan T. Abrams
Brian J. Fleming
Brian J. Fleming

On October 7, 2026, the U.S. Department of the Treasury announced the first civil penalty under its Outbound Investment Security Program (OISP). Treasury imposed a $200,000 penalty on Amidi, LLC in July 2026 for failing to submit a required notification of an investment into a Chinese AI company by Amidi’s controlled foreign entity.

According to Treasury, Amidi’s China-based fund invested approximately $92,478 in Shanghai Qiongche Intelligent Technology Company Limited (Noematrix) on April 19, 2025. Noematrix is a private Chinese company that develops AI, robotics, and embodied intelligence. According to Treasury, it identified the transaction “as part of its regular and ongoing compliance and market monitoring efforts.”

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