On December 18, 2025, President Trump signed into law the Fiscal Year 2026 National Defense Authorization Act (“NDAA”) that contains in Title LXXXV a revised version of the previously introduced Comprehensive Outbound Investment National Security Act (“COINS Act”). The COINS Act codifies and expands the existing Outbound Investment Security Program (“OISP”) that restricts US outbound investment in certain sensitive technologies. The NDAA passed Congress with significant support reflecting bipartisan consensus to implement an outbound investment review program…
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