OSIP
Kharon Webinar

Decoding Treasury's First OISP Penalty and the COINS Act Roadmap

About 1 hour

About this webinar

On Oct. 22, 2026, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (NPRM) to implement the Comprehensive Outbound Investment National Security Act of 2025 (COINS Act), which gave the Outbound Investment Security Program (OISP) a statutory basis in December 2025. If finalized, the proposed regulations would extend the program beyond China, Hong Kong, and Macau to include four additional countries of concern, and would add biotechnology, hypersonic systems, and high-performance computing and supercomputing as covered sectors. Until a final rule takes effect, the current OISP rules remain in force.

Join Kharon’s Olivia Valone and Andrew Sobotka alongside Winston Taylor’s Darshak Dholakia for a briefing on the proposed COINS Act regulations and lessons from Treasury’s first OISP civil penalty for investors adapting their screening and due diligence workflows.

Topics will include:

  • Expanded jurisdictions and sectors: How four additional countries of concern and three new sectors would change pre-transaction diligence, and what the proposed prohibition on all super intelligence development would mean for artificial intelligence (AI) investments.

  • Fund structures and indirect investment: Why an investment in a fund that already holds interests in covered foreign persons may itself be an indirect covered transaction, what extending the "knowingly directing" standard to notifiable transactions would mean for U.S. decision-makers at non-U.S. funds, and the proposed removal of the busines...

Investment RiskOutbound InvestmentsWebinar

Speakers

  • D Arshak

    Darshak Dholakia

    Partner

    Winston Taylor LLP

  • Olivia Valone

    Olivia Valone

    Strategic Growth Director

    Kharon

  • Andrew Sobotka

    Andrew Sobotka

    Senior Advisor

    Kharon

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