Outbound Investment Regulations: Exposure Draft May 4, 2026

This Market Advisory updates the Market Advisory issued on January 2, 2025, to address regulations issued by the Department of the Treasury (“Treasury”) to restrict U.S. outbound investment in countries of concern and provides examples of provisions which members may include, where relevant, in credit agreements and/or security or pledge agreements, as applicable. Although the regulations have not been modified since the previous Market Advisory, there have been two significant developments in the interim, one or both of which will result in amendments to the regulations. This updated Market Advisory is therefore intended to help members prepare for the pending changes.

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Elizabeth Yazgi

Assistant General Counsel

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