Treasury Department Issues First Civil Penalty under the Outbound Investment Security Program
Thursday, October 15, 2026 · first reported by JD Supra
Treasury's first civil enforcement penalty under the Outbound Investment Security Program (OISP) was announced on October 7, 2026.
Pillsbury's Global Trade & Sanctions Law team, in a JD Supra post, calls the action a reminder for three groups: U.S. investment vehicles, U.S. managers who run funds overseas, and U.S. companies that control subsidiaries abroad. In its view, their OISP diligence and documentation should reach the foreign entities they control, including when the investments are small or are follow-ons.
- Asset class
- Private equity
- Geography
- North America
The summary and fields above are extracted from the published reports and can contain errors. The linked articles are the source of record.
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