The Comprehensive Outbound Investment National Security (COINS) Act Congress Takes on Outbound Investment Regulation

December 24, 2025

The Comprehensive Outbound Investment National Security Act of 2025 (the "COINS Act"), which President Trump signed into law on December 18, 2025, codifies and expands the U.S. legal authority to regulate outbound investment — i.e., capital flowing out of the United States — to protect U.S. national security.  This marks a further commitment to U.S. outbound investment regulation following implementation of the U.S. Outbound Security Investment Program in January 2025, which was adopted pursuant to an Executive Order signed by President Biden.  The COINS Act authorizes prohibition of certain U.S. investments in companies engaged in specified sensitive technology activities, requires notification of other investments in these areas, and provides the President authority to impose sanctions against covered foreign persons.  The COINS Act also provides the flexibility to add additional covered technology sectors in the future, which is consistent with the clear indications from the Trump Administration that the OISP regulations issued earlier this year were just a starting point for regulating outbound investment to address U.S. national security concerns.

Significantly, the COINS Act authorizes $150 million to the U.S. Department of the Treasury for each of the next two fiscal years. This budget is an indication that Treasury will be able to deploy significant resources to further develop, implement, and enforce the OISP.  For comparison, the budget for the Committee on Foreign Investment in the United States (CFIUS) (including fees collected), which reviews foreign investments in American businesses and real estate for potential national security risks, was approximately $45 million in fiscal year 2025.

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