Clifford Chance

The First Six Months of the U.S. Outbound Investment Security Program: A Robust Start with Signs of Upcoming Expansion

July 17, 2025

On January 2, 2025, the U.S. Department of the Treasury’s (“Treasury”) regulations implementing the U.S. Outbound Investment Security Program (“OISP”) entered into force, establishing prohibition and notification requirements for certain transactions by U.S. persons with or for the benefit of China (including Hong Kong and Macau). The OISP focuses on outbound investment transactions related to semiconductors and microelectronics, quantum information technologies, and certain artificial intelligence (“AI”) systems.

Though the OISP is only six months old, it has emerged as a key regulatory regime that must be considered when engaging in certain transactions. Moreover, all indications are that the Trump administration intends to expand the scope of the OISP. Accordingly, on the OISP’s half-birthday, we summarize the major trends and developments since its inception.

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