OISP

Treasury’s first outbound-investment penalty exceeds value of underlying investment

Posted 10/7/26

The case shows that even a small investment through an overseas subsidiary can expose a U.S. parent to substantial penalties. Treasury fined Amidi more than twice the underlying investment’s value for a missed notification, underscoring the need for investors and counsel to identify covered transactions across foreign funds and subsidiaries, document their diligence and meet filing deadlines—even when an investment is permitted.

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