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10.28.26
New COINS of the Realm: Treasury’s Implementation of COINS Act Reaches Biotech, AI, and More
On Thursday, October 22, 2026, the U.S. Department of the Treasury (Treasury) issued a notice of proposed rulemaking (the Proposed Rule) to replace and expand the current Outbound Investment Security Program (the OISP). The Proposed Rule would implement Subtitle C of the Comprehensive Outbound Investment National Security Act of 2025 (the COINS Act) enacted last December, which we previously discussed here. The Proposed Rule would establish new regulations (to be codified at 31 C.F.R. Part 851) that prohibit U.S. persons from making certain investments, and require them to notify Treasury of others, when the target is a company or other person tied to the People’s Republic of China (PRC, including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, or (in specified circumstances) Venezuela (each such company or other person being a “covered foreign person”) that is engaged in specified technologies. Comments on the Proposed Rule are due December 7, 2026.
Press Releases
10.14.26
Wilson Sonsini Strengthens Leading National Security and Trade Practice with Veteran Ted Posner
Contact:
Kimberly Brooks
212-453-2881
kbrooks@wsgr.com
Kimberly Brooks
212-453-2881
kbrooks@wsgr.com