David is a law clerk in the International Trade practice group; he is not admitted to the practice of law.

On October 26, 2026, the Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPR”) that would implement Subtitle C of the Comprehensive Outbound Investment National Security Act (“COINS Act”) to expand the coverage of the existing Outbound Investment Security Program (“OISP”) (see Update of October 8, 2026).

The OISP came…

On October 7, 2026, U.S. Department of the Treasury (“Treasury”) announced that it imposed its first civil penalty of $200,000 against U.S. company Amidi LLC (“Amidi”) under the Outbound Investment Security Program (“OISP”). The OISP came into effect on January 2, 2025, requiring that U.S. persons notify Treasury of certain types of investments, whether made…

On September 27, 2026, the White House announced a reciprocal list of U.S. and Chinese imports recommended for reduced tariff treatment (“30-for-30”) as part of the first major outcome of the U.S.-China Board of Trade. The U.S.-China Board of Trade was first announced on June 2, 2026, to manage bilateral trade and to identify specific…