Treasury’s First Outbound Investment Penalty: $200,000 Against Amidi LLC
On October 7, 2026, the U.S. Department of the Treasury announced the first civil penalty issued under its Outbound Investment Security Program (OISP): $200,000 against Amidi LLC, the U.S. parent company of the organization known as Plug and Play Tech Center, for failing to notify Treasury of an investment its Chinese fund subsidiary made in a Chinese embodied artificial intelligence company.
The underlying investment was approximately $92,478. U.S. investors, venture funds, accelerators, and corporates with offshore investment vehicles should take note: the notification obligation reaches transactions by a U.S. person’s controlled foreign entities, and Treasury has now penalized a missed filing on a small deal.
Key Takeaways
- Treasury imposed a $200,000 civil penalty on Amidi LLC for failing to notify Treasury of an investment of approximately $92,478 in a Chinese AI and robotics company.
- The investment was made by Amidi’s Chinese fund subsidiary. The OISP regulations require a U.S. person to notify Treasury of a notifiable transaction by its controlled foreign entity.
- The current rules contain no general de minimis threshold for notification, and the existing regulations at 31 CFR Part 850 remain in effect while Treasury implements the COINS Act.
What Happened
On April 19, 2025, a Chinese fund owned by Amidi invested approximately $92,478 in Shanghai Qiongche Intelligent Technology Company Limited (Noematrix), […]
