What happened
On 7 October 2026 Treasury announced its first civil penalty under the Outbound Investment Security Program (OISP, effective 2 Jan 2025): $200,000 against US company Amidi LLC for failing to file a required notification after its Chinese fund subsidiary invested ~$92,478 in Shanghai Qiongche Intelligent Technology Co. (Noematrix), a Chinese embodied-AI/robotics developer. Treasury flagged that the COINS Act (Dec 2025) will expand OISP jurisdiction to additional countries and technology sectors.
Why it matters
This is the first binding enforcement under the US outbound-investment regime targeting AI-sector investments in China. It signals Treasury is actively scanning for un-notified AI investments and will sanction non-compliance, adding real compliance risk to US-person and controlled-foreign-entity participation in Chinese AI ventures.
Action needed
US persons and US-controlled foreign entities should audit existing and planned investments in Chinese/HK/Macau AI, quantum and semiconductor companies for OISP notifiable or prohibited transactions, and establish a filing and monitoring process to avoid similar penalties.