Will the BIOSECURE Act Be Expanded? What Comes Next
The BIOSECURE Act is often read as the finish line for US regulation of Chinese biotech. In a recent Open Door Salon conversation, Theresa Campobasso, a former US Marine Corps intelligence officer who was then SVP at Aardwolf Global, made the case that it is closer to the starting line, and explained where the rules are most likely to widen next.
What BIOSECURE covers today
Campobasso described the five companies the bill was built around.
"It is an act that is focused on five Chinese companies: BGI or Beijing Genomics Institute, MGI Tech, WuXi AppTec, WuXi Biologics, and Complete Genomics. If you are a company in the US that has any federal contracts, you may not use those five companies for genomic sequencing, for any drug-development services, for anything that touches American patient data."
The law Congress enacted in December 2025 names none of them. It works from a government list. A biotechnology company of concern is a company on the Pentagon's list of Chinese military companies that OMB identifies as a biotech supplier. That list includes BGI and MGI Tech. WuXi AppTec was added in June 2026, but in August a federal court barred the government from enforcing that designation while the company's challenge proceeds. The Office of Management and Budget can designate others, and its first full list is due by December 18, 2026. Once its rules take effect, federal agencies may not buy biotech equipment or services from those firms, may not contract with companies that use them on the contract, and may not let grants or loans pay for them (Arnold & Porter has the details). By her reading, that list is where the rules start.
Why it is an early signal, not the end
The gap, in her telling, is between the size of the problem and the size of the current law.
"I absolutely do believe that the BIOSECURE Act is not the end-all be-all. I believe it should instead be seen as an early signal of where the regulatory environment is going. Because the problem it was intended to resolve is so much larger than those five companies and those three use cases, I think we're going to see that regulatory perimeter expand."
Her reading is that the narrow scope is a first step.
Expansion axis one: more entities
The first place Campobasso expects growth is the covered-entity list itself, and she notes the pressure is already visible in Congress.
"I think we'll see more and more of these letters, more and more either specific names or types of entities or use cases added to legislation."
A short, named list is easy to plan around by avoiding a handful of companies. The enacted law already traded names for a list the government can add to, which removes that escape hatch.
Expansion axis two: more use cases
The second, and in her view more consequential, expansion is in what the rules cover.
"There are a couple key areas where US companies do have a lot of business and research relationships that are not included right now: active pharmaceutical ingredients or APIs, raw materials, the chemical precursors that most drugs are built from. Right now those are free and clear."
Those inputs sit at the base of the drug-manufacturing chain, and they are precisely where US dependence on a small number of overseas sources is deepest, which is what makes them the obvious next target.
The investment-side companion: the COINS Act
BIOSECURE expanding is only half the picture. Campobasso points to a parallel House bill that would add biotech to the COINS Act, extending the same logic from procurement to investment and putting US licensing deals, joint ventures, and equity in Chinese biotech under Treasury review. Read together, the two trace a single direction: the regulated line is widening on both the buying side and the investing side at once.
How to read where it is headed
Campobasso argues this is more predictable than it looks, if you watch the right sources.
"The way I try to stay up on it is I will set some automation to flag different articles as they get published. As hearings are published, you can read those and get a great sense of the follow-on actions and the topics that are being discussed."
What the original five names signal
The specific names on the list are less important than the logic behind them. The uses she named, genomic sequencing, drug-development services, and anything touching American patient data, point at the categories regulators consider most sensitive: the places where Chinese access to US biological and health data, or to the pipeline that produces it, carries the clearest national-security weight. Read that way, the five companies were examples of a broader concern. The same logic applied consistently reaches well beyond the original list.
Why planning around names is a trap
That is the practical danger for a company building its strategy around the current list. Avoiding five named firms was straightforward; it was also brittle. OMB must review its list at least once a year, so a plan built on dodging specific names collapses the moment the list changes. Campobasso's argument is that the durable response is to understand a partner's actual structure, funding, and government ties, the things that would land it on any future list.
When the conversation in those texts turns to APIs or medtech, she says, that is the tell. Whether or not the BIOSECURE Act itself is amended, the companies mapping their exposure against where the line is heading will have the most room to adjust. That is the conversation Open Door Salon exists to host. You can work with us here.
Raja Mikkili and Anne Herold Li take up the same exposure from the security side in a later conversation on why nation states target small biotechs, arguing that the companies most at risk are the ones that assume they are too small to be worth the trouble.
This piece is drawn from the recorded, on-the-record conversation with Theresa Campobasso on Open Door Salon. The BIOSECURE Act became law in December 2025; the bill to add biotechnology to the COINS Act was still a proposal in October 2026.