美国财政部对Amidi LLC开出首张OISP罚单

WASHINGTON, DC – In July 2026, the U.S. Department of the Treasury (Treasury) issued its first civil penalty under the Outbound Investment Security Program (OISP).  Treasury penalized Amidi, LLC (Amidi) $200,000 for failing to submit a required notification of an investment by its controlled foreign entity into a Chinese embodied artificial intelligence company.  The OISP, which became effective on January 2, 2025, currently requires notification to Treasury of certain types of investments and prohibits certain other types of investments by U.S. persons into entities in or connected to the People’s Republic of China, the Special Administrative Region of Hong Kong, and the Special Administrative Region of Macau that are engaged in certain activities in the quantum computing, artificial intelligence, and semiconductor sectors.  In addition, a U.S. person is required (a) to file a notification with Treasury regarding any transaction by its controlled foreign entity if the transaction would be notifiable if engaged in by a U.S. person and (b) to take all reasonable steps to prohibit and prevent transactions by its controlled foreign entity if the transaction would be prohibited if engaged in by a U.S. person.

On April 19, 2025, Amidi’s subsidiary, a Chinese fund, invested approximately $92,478 in Shanghai Qiongche Intelligent Technology Company Limited (Noematrix).  Amidi is also the parent entity of the organization that does business as Plug and Play Tech Center.  Noematrix is a private Chinese company that develops artificial intelligence, robotics, and embodied intelligence.  

“Today’s penalty announcement under the Outbound Investment Security Program underscores Treasury’s commitment to safeguarding U.S. national security through robust investment security measures that preserve America’s technological leadership and advance President Trump’s America First Investment Policy,” said Secretary of the Treasury Scott Bessent. 

“The Outbound Investment Security Program is an important tool aimed at addressing the advancement of key technologies by countries of concern that could pose risks to U.S. national security,” said Assistant Secretary of the Treasury for Investment Security Christopher Pilkerton.  Pilkerton added, “We will continue to ensure that investors comply with the requirements established under the program.”   

The issuance of the penalty highlights Treasury’s commitment to compliance with OISP rules.  Treasury identified this transaction as part of its regular and ongoing compliance and market monitoring efforts.  On December 18, 2025, Congress passed the Comprehensive Outbound Investment National Security Act of 2025 (COINS), which will expand OISP jurisdiction to include investments in additional countries and technology sectors.  In assessing compliance and whether to bring an enforcement action in connection with a particular transaction, Treasury will evaluate the facts and circumstances surrounding the conduct, including the aggravating and mitigating factors described in the Outbound Investment Security Program Enforcement Overview and Guidance. 

If anyone believes that a violation may have occurred, the Treasury Department encourages them to submit tips, referrals, or other relevant information to the Outbound Program tips line: [email protected].

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