Codifying the Outbound Investment Security Program - The 2025 COINS Act’s impacts on prohibited and notifiable US outbound investments

On December 18, 2025, the 2026 National Defense Authorization Act was signed into law. Among its provisions is the Comprehensive Outbound Investment National Security Act of 2025, referred to by its acronym, the COINS Act. While the COINS Act codifies the Outbound Investment Security Program (OISP) established in 2023 during the Biden administration by executive order, it does not make any immediate changes to the OISP nor to regulations previously issued by the US Treasury Department to... By: Herbert Smith Freehills Kramer