Regulation

COINS Act Codifies and Expands Outbound Investment Rules

Issue 60
January 2026

Author
Brian FlemingEvan AbramsPhil Capers
+ About author

Brian Fleming is a Partner at Steptoe. www.steptoe.com

Evan Abrams is an Associate in the Washington, DC office of Steptoe. www.steptoe.com

Phil Capers is an associate, Evan Abrams and Brian Fleming are partners at Steptoe in Washington, D.C.

On December 18, 2025, President Trump signed the National Defense Authorization Act for Fiscal Year 2026 (NDAA), which included the Comprehensive Investment National Security Act (COINS Act or the Act). The Act codifies and expands the existing U.S. Outbound Investment Security Program (OISP). The current OISP prohibits or requires notification of certain investments by U.S. persons involving entities linked to China and engaged in activities related to semiconductors, AI systems, and quantum in...

Continue reading

SUBSCRIBED FEATURES

  • Export Compliance Manager Tackles the issues and challenges that keep trade compliance professionals awake at night... with insight and with solutions.
  • Export Compliance Manager Shares the know-how of experienced professionals, keeping its readers on top of developing best practice in trade compliance AND helping to deliver real commercial advantage.
  • Export Compliance Manager Celebrates the valuable contribution of trade compliance professionals to their companies, communities and to international security.

SUBSCRIBELOGIN

Jonny Test