The existing rule remains in force. Treasury's December 23, 2025 FAQs confirm that the regulations effective January 2, 2025 will stay in effect until Treasury issues new regulations implementing the COINS Act. Treasury has 450 days from enactment to do so, a deadline of roughly mid-March 2027. The executive branch must also identify additional technologies for coverage, and the scope of covered foreign persons is broadened. Treasury has not yet published those technologies or the new definitions.
For compliance teams, the expanded coverage of affiliated persons and indirect investments means older manuals are more likely to have gaps. Law firm commentary through mid-2026 urges companies to redesign investment compliance frameworks, with particular attention to due diligence protocols. Until Treasury's new rules take effect, the current regulations govern, so teams should audit their procedures against them now and track the rulemaking as it moves toward the 2027 deadline.