Addressing the Outbound Investment Security Program (OISP)

On February 21st, the White House issued the America First Investment Policy Memorandum stating that the U.S. will “use all necessary legal instruments [to include the imposition of sanctions or other actions] to further deter United States persons from investing in the PRC’s military-industrial sector.” 

The new OISP rule (effective January 2025) introduces new restrictions and notification requirements, covering three categories of advanced technology and products: semiconductors and microelectronics, quantum information technologies, and artificial intelligence systems.

As industry develops controls to comply with current requirements, the regulatory landscape is evolving rapidly. The memorandum signals potential expansions to outbound investment restrictions, targeting additional sectors “implicated by the PRC’s national Military-Civil Fusion strategy.”

Join Kharon for a 30-minute Quick Take on the Outbound Investment Security Policy rule. The session includes a discussion on best practices for addressing the rule’s “knowledge standard” to conduct “reasonable transactional due diligence, including review of public and non-public information.”  We also address how to best prepare for the likelihood of new requirements, as policymakers, regulators, and legislators contemplate further deterrence measures to counter the People’s Republic of China’s (PRC) military-civil fusion strategies.  

Listen to expert insights to help inform the development and implementation of effective, defendable, and scalable outbound investment controls.