The U.S. Treasury Department has imposed a $200,000 fine on Amidi LLC for failing to disclose a $92,478 investment in Noematrix, a Chinese company focused on robotics and artificial intelligence. The penalty marks the first civil enforcement action under the government's outbound investment security program.

Treasury announced the penalty on Oct. 7, noting that the fine was formally issued in July. The underlying investment was made on April 19, 2025, by Amidi's Chinese fund subsidiary in Shanghai Qiongche Intelligent Technology Co., which operates under the name Noematrix. The target company develops artificial intelligence, robotics and embodied intelligence technologies. Amidi is also the owner of the organization operating as Plug and Play Tech Center, a Silicon Valley-based startup accelerator and venture investor.

According to the Treasury press release, the department identified the transaction through its ongoing compliance and market monitoring efforts after Amidi failed to submit the required notification.

First Enforcement Action Under New Rules

The Outbound Investment Security Program took effect on Jan. 2, 2025. The program was created under Executive Order 14105, signed in August 2023, which directed Treasury to prohibit or require notification for certain U.S. investments in sensitive technologies in countries of concern, with Treasury finalizing its implementing rules in late 2024. Under the program, U.S. persons must notify Treasury about certain investments involving sensitive technologies in China, Hong Kong and Macau. Some transactions in the artificial intelligence, semiconductor and quantum computing sectors are prohibited outright.

The rules also capture transactions executed through controlled foreign entities. When such a transaction would have triggered reporting requirements had it been conducted directly, U.S. investors must still file a notification.

Penalty Exceeds the Original Investment

At $200,000, the fine is more than twice the value of the underlying investment, a signal that even relatively small cross-border technology investments can carry significant compliance exposure.

The enforcement action centers on the failure to file the required notification. The case does not indicate that Treasury required Amidi to unwind the investment.

Treasury also said Congress passed the Comprehensive Outbound Investment National Security Act in December 2025. That legislation will expand the program's jurisdiction to additional countries and technology sectors.

The Amidi case offers an early indication of how Treasury intends to enforce the outbound investment rules. Companies investing in sensitive Chinese technologies now face greater pressure to assess their reporting obligations before completing transactions.