| Entity | Amidi, LLC |
|---|---|
| Counterparty | Shanghai Qiongche Intelligent Technology Company Limited (Noematrix) |
| Date | 7 Oct 2026 |
| Status | Civil penalty |
| Penalty | $200,000 |
| Region | U.S. & Allies |
In July 2026 the U.S. Department of the Treasury issued its first civil penalty under the Outbound Investment Security Program, assessing $200,000 against Amidi, LLC for failing to notify an investment by its controlled foreign entity.
On April 19, 2025, Amidi’s subsidiary, a Chinese fund, invested approximately $92,478 in Shanghai Qiongche Intelligent Technology Company Limited (Noematrix), a private Chinese company that develops artificial intelligence, robotics, and embodied intelligence. The release, dated October 7, 2026, states the violation as a missed notification, not as a prohibited transaction, and says Treasury identified the deal through regular compliance and market monitoring.
Who this affects
- For exporters: The release does not address export authorization. It describes OISP obligations on U.S. persons for certain investments, and on transactions by a controlled foreign entity, into entities in or connected to the People’s Republic of China, Hong Kong, or Macau in specified quantum computing, artificial intelligence, and semiconductor activities.
- For investors: A U.S. person must notify Treasury of a controlled-foreign-entity transaction that would be notifiable if the U.S. person engaged in it, and must take all reasonable steps to prohibit and prevent a controlled-foreign-entity transaction that would be prohibited if the U.S. person engaged in it. Amidi is also named as the parent entity of the organization that does business as Plug and Play Tech Center.
- For counsel/compliance: The stated violation is failure to submit a required notification. Treasury says it will weigh facts and circumstances, including aggravating and mitigating factors in the Outbound Investment Security Program Enforcement Overview and Guidance, when assessing compliance and whether to bring an action. The release does not state which factors were applied here, or how the $200,000 figure was set.
- For policymakers: The release states that on December 18, 2025, Congress passed the Comprehensive Outbound Investment National Security Act of 2025 (COINS), which will expand OISP jurisdiction to investments in additional countries and technology sectors.
The read
The first published OISP civil penalty is a notification case, not a prohibition case. The release describes the April 19, 2025 transaction as an investment by Amidi’s Chinese-fund subsidiary that required notice, and it does not describe that investment as prohibited.
The assessed amount, $200,000, is stated alongside an investment of approximately $92,478; the release does not explain the relationship between the two figures. Treasury says it found the transaction through ongoing compliance and market monitoring, and it points to a tips line at Outbound.Tips@treasury.gov. COINS is described only as a statute that will expand covered countries and technology sectors; no effective date or implementing schedule is given.
What was the action?
In July 2026 Treasury issued its first civil penalty under OISP, which became effective on January 2, 2025, and penalized Amidi, LLC $200,000. The stated ground is failure to submit a required notification of an investment by Amidi’s controlled foreign entity into a Chinese embodied artificial intelligence company. The announcement is dated October 7, 2026. No order number, case number, RIN, or Federal Register citation appears in the release.
What’s the penalty / scope, and how is it set?
The penalty is $200,000. The release does not state how it was calculated. The underlying transaction is an approximately $92,478 investment on April 19, 2025, by Amidi’s subsidiary, a Chinese fund, in Shanghai Qiongche Intelligent Technology Company Limited (Noematrix). OISP, as described, requires notification of certain investments and prohibits certain others by U.S. persons into covered entities in the People’s Republic of China, Hong Kong, and Macau in quantum computing, artificial intelligence, and semiconductors, and it extends notification and prevention duties to transactions by a controlled foreign entity.
Who else is exposed?
Named in the transaction path: Amidi’s subsidiary, a Chinese fund, which made the investment, and Noematrix, the investee. The fund is not named. Amidi is identified as the parent entity of the organization that does business as Plug and Play Tech Center; the release does not penalize that organization. The program description covers U.S. persons and their controlled foreign entities for specified activities in quantum computing, artificial intelligence, and semiconductors tied to the People’s Republic of China, Hong Kong, and Macau. Other investors in Noematrix are not specified in the record.
What happens next
The release states that COINS, passed December 18, 2025, will expand OISP jurisdiction to additional countries and technology sectors. It does not give an effective date. Treasury says future actions will turn on facts and circumstances and on the aggravating and mitigating factors in the Outbound Investment Security Program Enforcement Overview and Guidance. It directs tips and referrals to Outbound.Tips@treasury.gov. No payment deadline, appeal window, or further proceeding against Amidi is stated.
Treasury penalized Amidi, LLC (Amidi) $200,000 for failing to submit a required notification of an investment by its controlled foreign entity into a Chinese embodied artificial intelligence company.Treasury Press Release sb0652, 2026 →