Treasury Imposes First Outbound Investment Penalty Against Amidi LLC
In July 2026, the U.S. Department of the Treasury issued its first civil penalty under the Outbound Investment Security Program, fining Amidi LLC $200,000 for an unnotified Chinese tech investment, thompsonhinesmartrade.com reported. The enforcement action marks the initial penalty under federal rules established to screen American capital flowing into sensitive sectors in countries of concern.
The penalty stems from an April 19, 2025, transaction in which Amidi’s Chinese subsidiary invested approximately $92,478 in Shanghai Qiongche Intelligent Technology Company Limited, also known as Noematrix, according to home.treasury.gov. Noematrix is a private Chinese firm that develops artificial intelligence, robotics, and embodied intelligence. Amidi is also the parent entity of the organization that operates Plug and Play Tech Center.
Compliance Failures Under the Outbound Investment Security Program
The Outbound Investment Security Program took effect on January 2, 2025, requiring U.S. persons to notify the Treasury Department of certain investments into entities connected to China, Hong Kong, and Macau within sensitive technology sectors like quantum computing, artificial intelligence, and semiconductors. Treasury stated that Amidi violated program rules by failing to notify the agency of a transaction conducted through a controlled foreign entity and failing to take all reasonable steps to prevent it.
Treasury officials discovered the violation through regular compliance and market monitoring efforts. In announcing the penalty, Secretary of the Treasury Scott Bessent stated that the action shows the administration's commitment to safeguarding national security and advancing America First investment policies, home.treasury.gov reported. Assistant Secretary for Investment Security Christopher Pilkerton added that the agency will continue to ensure investor compliance across all designated markets.
Future Jurisdiction Expansion Under the COINS Act
Federal oversight of foreign investments is scheduled to broaden significantly following the passage of the Comprehensive Outbound Investment National Security Act of 2025 on December 18, 2025. The legislation extends the program’s geographic scope beyond China, Hong Kong, and Macau to include Cuba, Iran, North Korea, Russia, and Venezuela under the Maduro regime. It also adds hypersonic systems, high-performance computing, and supercomputing to the list of sensitive technology sectors.
The expanded jurisdiction will take effect once the Treasury Department completes implementing regulations, a process mandated to conclude no later than March 13, 2027. Treasury evaluates compliance and enforcement actions using specific aggravating and mitigating factors outlined in its published enforcement guidance, and encourages industry participants to submit tips regarding potential violations to Outbound.Tips@treasury.gov.
Frequently Asked Questions About the Treasury Penalty
What specific sector does Noematrix operate in?
Noematrix develops artificial intelligence, robotics, and embodied intelligence, according to home.treasury.gov. The private Chinese company received an investment of approximately $92,478 from Amidi’s Chinese fund subsidiary on April 19, 2025.
When must the Treasury complete rules for the COINS Act?
The Treasury Department must complete implementing regulations for the Comprehensive Outbound Investment National Security Act of 2025 no later than March 13, 2027, which is 450 days after the legislation passed on December 18, 2025.