# Treasury Enforces Outbound Investment Rules

Treasury announced its first civil penalty under the Outbound Investment Security Program after Amidi, LLC failed to notify the department of a covered investment. Under the currently operative 31 CFR Part 850, U.S. persons may have notification and prevention duties for covered investments made by controlled foreign entities, including certain small investments and third-country joint ventures. Contractors and investors with relevant foreign subsidiaries, funds, or joint ventures should assess whether their transactions are covered; required notices are due within 30 calendar days, and supporting records must be retained for 10 years. The report does not establish a new procurement eligibility rule, and implementing regulations for the COINS Act are forthcoming.

- Companies with foreign subsidiaries, funds, or joint ventures should screen relevant transactions against Part 850 and document their diligence and controls; duties depend on whether a transaction is covered.
- Violations may lead to civil penalties, criminal referral for willful conduct, or transaction nullification or divestment, creating potential legal and transaction risks for contractors and investors.
- The enforcement action signals that investment-related controls can apply even to small investments or third-country joint ventures. The reported COINS Act regulations have not yet been issued.

**Jurisdictions:** federal
**Topics:** Regulatory Compliance
**Published:** October 12, 2026

### Government Entities
- U.S. Department of the Treasury (Treasury)

### Vendors
- Amidi, LLC (Entity penalized for failing to notify Treasury of a covered investment)

### Sources
- [Treasury Takes Action in Outbound Investment Violation | Brownstein Hyatt Farber Schreck - JDSupra](https://www.jdsupra.com/legalnews/treasury-takes-action-in-outbound-9670965) - JD Supra