The US Treasury Department has initiated enforcement of the Outbound Investment Security Program (OISP), according to Laura Black, a partner at White & Case. In an article for Foreign Investment Watch, Black discussed the ongoing review by the Trump administration regarding potential modifications or rescission of the program.
Reports indicate that the Treasury Department has contacted US venture capital and private equity firms about investments that may fall under OISP-covered transactions. This outreach involves comments and questions on notifications voluntarily submitted by US investors.
Black confirmed this approach, stating, “I can confirm that Treasury is reaching out with comments and questions on notifications that US investors have voluntarily submitted… in a manner similar to Treasury’s approach with respect to CFIUS filings.”
Additionally, Black offered advice on notification requirements when multiple US investors are involved in a funding round. She emphasized the importance of accuracy and coordination among investors: “While each investor must ensure the accuracy of the information they submit, I would recommend coordination on the portions of the notification relating to the target to ensure consistency and to reduce follow-up questions.”
