Reliably transferring treatment policies learned in one clinical environment to another is currently limited by challenges related to domain shift. In this paper we address off-policy learning for sequential decision making under domain shift -- a scenario susceptible to catastrophic overconfidence -- which is highly relevant to a high-stakes clinical settings where the target domain may also be data-scarce. We propose a two-fold counterfactual regularization procedure to improve off-policy learning, addressing domain shift and data scarcity. First, we utilize an informative prior derived from a data-rich source environment to indirectly improve drawing counterfactual example observations. Then, these samples are then used to learn a policy for the target domain, regularized by the source policy through KL-divergence. In simulated sepsis treatment, our counterfactual policy transfer procedure significantly improves the performance of a learned treatment policy.