U.S. Outbound Investment Screening Program

In December 2025, the U.S. Congress passed the FY2026 National Defense Authorization Act (NDAA), which includes the Comprehensive Outbound Investment National Security (COINS) Act. The COINS Act codifies key elements of the U.S. Treasury Department’s Outbound Investment Screening Program (OISP), which has been in effect since January 2025, and makes targeted changes that expand the scope of the program while largely preserving the existing framework.

For LPs, the key points of compliance remain mostly unchanged. The legislation does not apply to LP investments in U.S. pooled funds, where responsibility for adherence to the program rests with U.S. general partners (GPs), and LPs investing with non-U.S. managers may continue to rely on existing safe harbors, including contractual assurances. The Secretary of the Treasury is authorized to define covered sectors and notification requirements within 450 days of enactment; until that time, LPs should continue to follow the notification requirements under OISP with consideration of the new sectors and countries of concern identified by the NDAA.

The ILPA summary below provides additional detail on key changes, provisions that remain unchanged, and considerations for LPs, in addition to other supporting resources.