Treasury proposes broader outbound-investment controls across six jurisdictions

On October 26, 2026, the U.S. Treasury Department published a proposed rule implementing the Comprehensive Outbound Investment National Security Act, after announcing the proposal on October 22; comments are due December 7, 2026. The proposal would cover China, Hong Kong, Macau, Cuba, Iran, North Korea, Russia and Venezuela under Nicolás Maduro and addresses semiconductors, AI, quantum technology, high-performance computing, hypersonic systems and specified biotechnology. Transaction teams should add an outbound-investment classification step to private equity, joint venture, lending and technology-transfer diligence, with particular attention to indirect ownership and controlled foreign entities. The expansion from a China-centred regime to a multi-jurisdiction framework increases the value of reusable diligence taxonomies that can be applied before exclusivity or signing.