This newsletter is a listing of the latest changes in export control regulations through February 28, 2026.  The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

 

See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and

persons denied export privileges by the United States Government.

 

In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.

 

REGULATORY UPDATES

 

President

 

Continuation of the National Emergency With Respect to the Situation in Burma

February 3, 2026, 91 Fed. Reg. 5663.  On February 3. 2026, the President issued a notice continuing for another year the national emergency declared on February 10, 2021 in EO 14014 in relation to Burma.

 

https://www.federalregister.gov/documents/2026/02/06/2026-02497/continuation-of-the-national-emergency-with-respect-to-the-situation-in-and-in-relation-to-burma

 

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Establishing An American First Arms Transfer Strategy

 

February 6, 2026: President Trump issued an Executive Order (EO 14383) Establishing an American First Arms Strategy, in which the policy of the U.S. is to intentionally use arms transfers as a tool of American foreign policy and to expand strategically relevant industrial production capacity in the U.S. by:

(a)  establishing an America First Arms Transfer Strategy that provides clear direction and implementation guidance to arms transfer stakeholders; and

(b) streamlining processes across executive departments and agencies (agencies) to strengthen effectiveness and create efficiencies in our defense sales enterprise.

 

An America First Arms Transfer Strategy.

(a)  An America First Arms Transfer Strategy shall accomplish the following objectives:

• The United States will use arms sales and transfers to increase production and build production capacity for weapons and platforms the Secretary of War determines to be the most operationally relevant for executing the National Security Strategy (NSS);
• The United States will use foreign purchases and capital to support domestic reindustrialization, expand production capacity, and improve the resilience of the United States defense industrial base.  Arms sales and transfers will support Department of War (DoW) efforts to promote innovation and competition by incentivizing new entrants and nontraditional defense companies to contribute to the defense industrial base;
• The United States will use arms sales and transfers to reinforce DoW acquisition and sustainment activities, including by building critical supply chain resilience and avoiding adding to backlogs on priority components and end-items that impact United States or ally and partner readiness;
• Consistent with Executive Order 14268 of April 9, 2025 (Reforming Foreign Defense Sales to Improve Speed and Accountability), the United States will prioritize arms sales and transfers to partners that have invested in their own self-defense and capabilities, have a critical role or geography in United States plans and operations, or contribute to our economic security.

(b)  Within 120 days of the date of this order, the Secretary of War, in coordination with the Secretary of State and the Secretary of Commerce, shall submit to the President, through the Assistant to the President for National Security Affairs, a sales catalog of prioritized platforms and systems that the United States shall encourage our allies and partners to acquire.  The sales catalog shall be based on criteria identified in the America First Arms Transfer Strategy.

(c)  Within 120 days of the date of this order, the Secretary of Commerce, in coordination with the Secretary of State and the Secretary of War, shall provide recommendations to enhance advocacy efforts encouraging foreign procurement of defense articles produced in America for the purpose of supporting an America First Arms Transfer Strategy.

(d)  Within 120 days of the date of this order, the Secretary of State and the Secretary of War, in coordination with the Secretary of Commerce, shall identify Foreign Military Sales (FMS) and Direct Commercial Sales opportunities that will support the strategic objectives of the America First Arms Transfer Strategy and the growth of the United States defense industrial base.

(e)  Within 60 days of the date of this order, the Secretary of State and the Secretary of War, in coordination with the Secretary of Commerce, shall develop an industry engagement plan and submit it to the President, through the Assistant to the President for National Security Affairs, to enable the United States Government to fully coordinate with American stakeholders while executing the America First Arms Transfer Strategy.

 

Eliminating Inefficiencies in American Arms Transfers

In order to fully implement an America First Arms Transfer Strategy and streamline our defense sales process, the United States Government shall undertake the following actions:

• Within 90 days of the date of this order, the Secretary of War, in coordination with the Secretary of State, shall develop clear criteria for determining which weapons, platforms, or capabilities require Enhanced End Use Monitoring.  Additionally, the Secretary of State, the Secretary of War, and the Secretary of Commerce shall establish an End Use Monitoring coordination group, consisting of designees from each respective department, which will meet to improve the effectiveness and coordination of their respective department’s end-use monitoring activities.  These actions will improve information sharing and efficiencies to ensure allies and partners are complying with United States requirements and to reduce risk of diversion.
• Within 60 days of the date of this order, the Secretary of State, in coordination with the Secretary of War, shall review Third-Party Transfer (TPT) processes and submit a plan to the President through the Assistant to the President for National Security Affairs to reduce and potentially realign the onerous TPT process, with due consideration to technology security risks.
• Within 90 days of the date of this order, the Secretary of War, in coordination with the Secretary of State, shall develop a process to provide advanced notice, as appropriate, to allies and partners of upcoming contracting actions and associated deadlines for FMS Letter of Offer and Acceptance implementation.
• The Secretary of State, the Secretary of War, and the Secretary of Commerce shall ensure effective coordination when assessing the impacts of Direct Commercial Sales to the defense industrial base.
• To streamline Congressional notifications, Executive Order 13637 of March 8, 2013 (Administration of Reformed Export Controls) is hereby amended by revising section 1(j) and (k) to read as follows:“(j) Those under sections 36(a) Act (22 U.S.C. 2776(a)) to the Secretary of War.  The Secretary of War, in the implementation of the delegated functions under sections 36(a), shall consult with the Secretary of State.  With respect to those functions under sections 36(a)(5) and (6) (22 U.S.C. 2776(a)(5) and (6)), the Secretary of War shall also consult with the Director of the Office of Management and Budget.(k) Those under section 36(b)(1), (c) and (d) of the Act (22 U.S.C. 2776(b)(1), (c), and (d)) to the Secretary of State.  To ensure coordination, the Secretary of State shall notify the Secretary of War of the intent to formally notify the Congress of proposed arms transfers.”

 

Enhancing Accountability and Transparency

(a)  Within 30 days of the date of this order, the Secretary of State, the Secretary of War, and the Secretary of Commerce shall establish the Promoting American Military Sales Task Force (Task Force) to coordinate efforts to implement the America First Arms Transfer Strategy and enhance accountability and transparency throughout the arms transfer enterprise.  The Task Force shall:
(i)   be chaired by the Assistant to the President for National Security Affairs or his designee, and be  composed of the Under Secretary of Defense for Acquisition and Sustainment, the Under Secretary of State for Arms Control and International Security, the Under Secretary of Commerce for International Trade;

(ii)   develop a charter to clearly define the specific objectives and structure of the Task Force;

(iii)  include as ex officio members the Service Acquisition Executives of the military departments and representatives of other non-military implementing agencies as appropriate to report on actions taken by the military departments and other implementing agencies to accelerate the contracting of priority FMS cases and ensure exportability of identified priority systems; and

(iv)   convene quarterly, or as required, to review progress implementing the America First Arms Transfer Strategy, including whether targeted defense sales align with the Strategy’s objectives.

(b)  Within 120 days of the date of this order, and to further the reforms directed in Executive Order 14268, and to improve transparency for United States industry and partners and allies, the Secretary of State, the Secretary of War, and the Secretary of Commerce shall begin to publish aggregate quarterly performance metrics on FMS case development and execution, and on the adjudication of Commerce and State export licenses.

 

https://www.whitehouse.gov/presidential-actions/2026/02/establishing-an-america-first-arms-transfer-strategy/

 

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Addressing Threats to the United States by the Government of Iran

 

February 6, 2026: 91 Fed. Reg. 6493: On February 6, 2026, the President issued EO 14382 authorizing, effective the date of this order, an additional ad valorem rate of duty—for example, 25 percent— to be imposed on goods imported into the United States that are products of any country that directly or indirectly purchases, imports, or otherwise acquires any goods or services from Iran.  The order directs the Secretary Commerce to identify such countries and requires the Secretary of State, in consultation with Treasury, Commerce, Homeland Security, and the U.S. Trade representative to determine the specific tariff levels to apply.

 

https://www.whitehouse.gov/presidential-actions/2026/02/addressing-threats-to-the-united-states-by-the-government-of-iran/

 

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Modifying Duties To Address Threats to the United States by the Government of the Russian Federation

 

February 6, 2026: 91 Fed. Reg. 6501: On February 6, 2026, the President issued EO 14384 rescinding the U.S. tariff policy to impose an additional 25% ad valorem duty on imports from India. The President determined that India has taken actions to address U.S. National Security concerns by having committed to stop directly or indirectly importing Russian Federation oil, representing that it will purchase United States energy products from the United States, and has recently committed to a framework with the United States to expand defense cooperation over the next 10 years. The EO went into effect on or after 12:01AM on February 7, 2026.

 

https://www.whitehouse.gov/presidential-actions/2026/02/modifying-duties-to-address-threats-to-the-united-states-by-the-government-of-the-russian-federation-04b2/

 

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Continuation of the National Emergency With Respect to Ukraine

 

February 18, 2026: 91 Fed. Reg. 8355: On February 18, 2026, the President issued an Administrative Order continuing for 1 year the national emergency declared in Executive Order (EO) 13660. EO 13660, which was expanded in scope in EOs 13661, 13662, and 14065, and under which additional steps were taken in EOs 13685 and 13849, declared a national emergency, pursuant to the International Emergency Economic Powers Act, to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the actions and policies of persons that undermine democratic processes and institutions in Ukraine; threaten its peace, security, stability, sovereignty, and territorial integrity; and contribute to the misappropriation of its assets.

 

https://www.govinfo.gov/content/pkg/FR-2026-02-20/pdf/2026-03501.pdf

 

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Continuation of the National Emergency With Respect to Venezuela

 

February 18, 2026: 91 Fed. Reg. 8357:  On February 18, 2026, the President issued Administrative Order continuing for 1 year the national emergency declared in Executive Order (EO) 13692. EO 13692, under which additional steps were taken in EOs 13808, 13827, 13835, 13857, 13884, and 14245, declared a national emergency with respect to the situation in Venezuela, including the Government of Venezuela’s erosion of human rights guarantees, persecution of political opponents, curtailment of press freedoms, use of violence and human rights violations and abuses in response to antigovernment protests, and arbitrary arrest and detention of antigovernment protesters, as well as the exacerbating presence of significant government corruption.

 

https://www.govinfo.gov/content/pkg/FR-2026-02-20/pdf/2026-03502.pdf

 

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Continuing The Suspension Of Duty-Free De Minimis Treatment For All Countries

 

February 20, 2026: 91 Fed. Reg. 9433: On February 20, 2026 the President issued EO 14388 that continues the suspension of duty-free de minimis treatment for all countries as implemented in EO 14193, EO 14194, EO 14195, and EO 14257

 

https://www.whitehouse.gov/presidential-actions/2026/02/continuing-the-suspension-of-duty-free-de-minimis-treatment-for-all-countries/ and

https://www.federalregister.gov/documents/2026/02/25/2026-03829/continuing-the-suspension-of-duty-free-de-minimis-treatment-for-all-countries

 

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Ending Certain Tariff Actions

 

February 20, 2026: 91 Fed. Reg. 9437: On February 20, 2026 the President issued an EO 14389 directing the Secretary of Commerce, the Secretary of Homeland Security, and the United States Trade Representative, as appropriate and in consultation with the Commissioner of U.S. Customs and Border Protection, the Chair of the United States International Trade Commission, and any other senior official they deem appropriate to terminate the ad valorem duties imposed under IEEPA.

 

https://www.whitehouse.gov/presidential-actions/2026/02/ending-certain-tariff-actions/ and

https://www.federalregister.gov/documents/2026/02/25/2026-03832/ending-certain-tariff-actions

 

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Department of State, Directorate of Defense Trade Controls (DDTC)

 

DDTC Name And Address Changes Posted To Website

 

February 6 through February 27, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at:

https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&kb_number=KB0010093    

 

• Certain Honeywell International Inc. subsidiaries names and addresses that fall within Honeywell Aerospace Technologies changed their names and address due to corporate restructuring.
  • From: Honeywell Belgium NV

To: Honeywell Aerospace Belgium B.V.

• From: Hermes Plaza, Hermeslaan 1H, Diegem, 1831, Belgium

To: Hermes Plaza, Hermeslaan 1H, Diegem, 1831, Belgium

• From: Honeywell S.r.l. Via Vittor Pisani n. 6, Milan, 20124, Italy

To: Honeywell II S.r.l. Via Alessandro Volta 16 CAP, Cologno Monzese Milan, 20093, Italy

• From: Honeywell Co., Ltd. 4/F & 5/F Sangam IT Tower 1590 Sangam-dong, Mapo-gu, Seoul, 121-835, South Korea

To: Honeywell Aerospace Korea Ltd. 27F, 511, Yeongdong-daero, Gangnam-gu, Seoul, South Korea

• From: Honeywell (Vietnam) Company Limited V1405-1406, 14/F, Pacific Place, No. 83B Ly Thuong Kiet Street, Tran Hung Dao Ward; Hoan Kiem District, Hanoi, Vietnam

To: Honeywell Aerospace Vietnam Company Limited Office No. 1638, Register 02, Level 16, Daeha Business Center Building, No. 360, Kim Ma Street, Giang Vo Ward, Hanoi City, Vietnam

• Qnity Electronics, Inc. subsidiary acquisition and additions due to reorganization as follows:
  • Transferred: Qnity Electronics, Inc.; DuPoint de Nemours, Inc.; DuPoint Electronics USA, LLC; and Laid R&F Products, Inc.

To: Qnity Electronics, Inc. as subsidiaries.

• Add: EKC Advanced Electronics USA, LLC and Kalrez USA, LLC

To: Qnity Electronics, Inc. as subsidiaries.

• DSV Air & Sea, Inc. Entities Names and Locations Change Due to Restructuring

From: Schenker Deutschland AG Schlachte 15-18 28195 Bremen, Germany

To: DSV Air & Sea Germany GmbH Schlachte 15-18 28195 Bremen, Germany

• From: Schenker International S.A. de C.V. Av. Patriotismo no. 201, Piso 3, Col. San Pedro de los Pinos 15520 Mexico City, Mexico

To:  DSV Air & Sea, S.A. de C.V. Insurgentes Sur N0. 1271 Piso 4 03740 Mexico City, Mexico, and
DSV Contract Logistics S.A. de C.V. Av. Victor Hugo No 330 – D Col. Complejo Industrial Chihuahua 31136 Chihuahua, Mexico

• From: Schenker Korea Ltd. 97-49, Gonghangdong-ro 296beon-gil, Jung-gu Airp. 22379 Incheon, South Korea

To: DSV Air & Sea Ltd. 16th Floor, Hanssem Bldg. 179, Seongam-ro, Mapo-gu 03929 Seoul, South Korea, and
DSV Contract Logistics Ltd. 1203ho, Queens Park Ten, 66 Magokjungang 6-ro Gangseo-gu, Seoul, South Korea

• From: Schenker (L.L.C) 705, Al Masood Tower, Airport Road, Diera Dubai, United Arab Emirates
  To: DSV Air & Sea DWC-LLC Dubai World Central Dubai Logistics City Jebel Ali, 644305 Dubai, United Arab Emirates, and

DSV Contract Logistics L.L.C. PO Box – 36683, Dubai Investment Park, Dubai, U.A.E Dubai, United Arab Emirates

• Mitsubishi Electric Corporation changes in name to subsidiaries due to a reorganization as follows:
  • From: Tsuryo Technica Corporation and Ryosai Technica Corporation

To: Ryoshin Technica Corporation

• From: Ryoshin Technica Corporation

To: Mitsubishi Electric Infrastructure Technica Corporation

• Change in Address for PCC Airfoils LLC from 3401 Enterprise Parkway, Suite 200, Beachwood,               OH 44122 to 26800 Fargo Avenue, Suite 100k, Bedford Heights, OH 44146;
• DSV Air & Sea, Inc. changes in name and address due to restructuring
  • From: Schenker Australia Pty Ltd 72 – 80 Bourke Road 2015 Alexandria, Australia

To: DSV Air & Sea Pty. Ltd 47 Watson Drive 3045 Melbourne Airport Victoria, Australia; and

DSV Solutions Pty. Ltd 47 Watson Drive 3045 Melbourne Airport Victoria, Australia

• From: Schenker NV Noorderlaan 147 2030 Antwerp, Belgium

To: DSV Air & Sea NV Schoonmansveld 40, 2870 Puurs, Belgium; DSV Road N.V.  Schoonmansveld 40, B-2870 Puurs, Belgium; and DSV Contract Logistics NV Eddastraat 21, Kennedy Industriepark, 9042 Gent (St. Kruis-Winkel), Belgium

• From: Schenker do Brasil Transportes Internacionais Ltda. Rua Geraldo Flausino Gomes, 78-12 Andar CEP 04575-060 Sao Paulo, Brazil

To: DSV Air & Sea Brasil Ltda. Av.Jornalista Roberto Marinho,85 12 andar 04576-010 São Paulo, Brazil; and DSV Contract Logistics Brasil Serviços de Logística Ltda. Av. Jornalista Roberto Marinho, 85, 12o andar 04576-010 Sao Paulo, Brazil

• From: Schenker OY, Finland

To: DSV Air & Sea OY Trukkikuja 3, FIN-01360 Vantaa, Finland; DSV Road Oy Tikkurilantie 147 01530 Vantaa, Finland; and DSV Contract Logistics Oy Trukkikuja 3
FIN – 01360 Vantaa, Finland

• From: Schenker Deutschland AG Schlachte 15-18 28195 Bremen, Germany

To: DSV Solutions GmbH Schlachte 15-18 28195 Bremen, Germany

• From: Schenker Nederland B.V. Emma Goldmanweg 1 5000AS Tilburg, Postbus 718, Netherlands

To: Schenker Nederland B.V. Emma Goldmanweg 1 5000AS Tilburg, Postbus 718, Netherlands; and  DSV Contract Logistics B.V. Tradeboulevard 4, Havennr. 528 4761 RL Zevenbergen, Netherlands

• From: Schenker AS Alnabruveien 15 0668 Oslo, Norway

To: DSV Air & Sea AS Alf Bjerckes vei 10 0582 Oslo, Norway; and  DSV Road AS Toveien 35-39 1540 Vestby, Norway

• From: Schenker Transitarios, S.A. DSV Air Rua Florbela Espanca, n4, Casal Novo, Sao Juliao do Tojal 2660-364 Loures, Portugal

To: DSV Air and Sea Portugal, Lda PLLN-P.L Lisboa Norte Lote 19, Fracao A & B 2600-729 Vila Franca de Xira, Portugal; and DSV Transitarios Lda Rua Compo do Martelo, 319 P-4485-959 Vilar do Pinheiro, Portugal

• From: Schenker Singapore (PTE) Ltd. 17 Changi South Street 2 486129 Singapore

To: DSV Air & Sea Singapore Pte. Ltd. 163 Kallang Way, #09-11 to 18 349256 Singapore; and DSV Solutions Pte Ltd. 5 Changi North Way 498771 Singapore

• From: Schenker South Africa (Pty) Ltd. 1 and 2 Shiraz Close, JT Ross Park Plumbago 3, Witfontein Ext 54 1620 Kempton Park, South Africa

To: DSV South Africa (Pty) Ltd. DSV Park Gauteng, 16 Serengeti Boulevard, Witfontein X89 1620 Kempton Park 1620 Johannesburg, South Africa;  DSV Road (Pty) Ltd. DSV Park Gauteng, 16 Serengeti Boulevard, Witfontein X89 1620 Johannesburg, South Africa; and DSV Contract Logistics (Pty) Ltd. DSV Park Gauteng, 16 Serengeti Blvd, Witfontein X89 1620 Johannesburg, South Africa

• From: Schenker Logistics, S.A.U. Calle 4 No. 57-61 Sector C (Zona Franca) 08040 Barcelona, Spain

To: DSV Air & Sea S.A.U. Pol. Ind. Moli de la Bastida, c./Pagesia S/N 08191 Rubi – Barcelona, Spain; DSV Road Spain S.A.U. Pol Ind. Molí de la Bastida C. Pagesia S/N. 08191 RUBI – BARCELONA, Spain; and DSV Solutions Spain S.A.U. Pol.Ind. Molí de la Bastida C. Pagesia s/n. 08191 RUBI – BARCELONA, Spain

• From: Schenker Limited Schenker House Unit 3 LHR Portal Scylla Road TW6 3FE Middlesex, United Kingdom

To: DSV Road Ltd Scandinavia House, Refinery Road, Parkeston CO12 4QG Harwich Essex, United Kingdom; and DSV Contract Logistics Ltd Scandinavia House, Refinery Road, Parkeston CO12 4QG Harwich, Essex, United Kingdom

• From: Schenker, Inc 1305 Executive Blvd, Ste 200 Chesapeake, VA 23320

To: DSV Air & Sea, Inc. 200 South Wood Ave. Suite 300 Iselin, NJ 08830

• Change in Name from Mytilineos S.A to Metien Energy & Metals S.A. due to a corporate rebranding.
• Change in Name from GAL Air Navigation Services LLC to Global Air Navigation Services LLC as a result of corporate rebranding.

 

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DDTC Final Commodity Jurisdiction Determinations Posted To Website

 

February 3, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between December 31, 2025 and January 27, 2026, on its website at:

https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&kb_number=KB0011272

 

Model Name	Manufacturer	Description	Final Determination	Final Determination Date
SCHWACK Aerial Assault Units, Models SCHWACK 1 and SCHWACK-EBF, Part Numbers 1 and 2	Defensive Strategies Group	Battery Powered One Way UAVs	USML Category VIII(a)(5) when specially designed to incorporate a defense article; USML Category VIII(a)(16) otherwise	12/31/2025
Mann Barrels for Northrop Grumman chain guns (part numbers 465-1999-5, 465-5520-1, 465-5520-2, 465-5520-3, 465-5520-4, 465-5720, 465-8513, 12524502, X465-9647-1)	Northrop Grumman Corporation	Equipment used for testing ammunition for chain guns	USML Category II(j)(1)	12/31/2025
Combustion Chamber	Sintavia, LLC	Combustion chamber for use in a space launch vehicle	USML Category IV(h)(14)	12/31/2025
Saltenna Plasmonic Antenna (SPA) 1, 2, and 3	Saltenna, Inc.	Antennas that attach to existing radios for extended range	Seek a CCATS	12/31/2025
Hybrid Laser Rangefinder Receiver Module, Model 758-04	Analog Modules, Inc., a HEICO Company	Laser rangefinder receiver	USML Category XII(e)(21)	12/31/2025
SVX “Wyvern,” Model SVX-RFPV 001	Vorotnik LLC dba SkyVaultex LLC	Small multi-rotor UAV	Seek a CCATS	12/31/2025
Second Stage Turbine Disk (PN 4073102) and Front Turbine Case and Duct (PN 4081800)	Defense and Development Enterprises, LLC dba D&D Enterprises, LLC	Components of the F100-220 engine	Second Stage Turbine Disk:  USML Category XIX(f)(2); Front Turbine Case and Duct: Seek a CCATS	12/31/2025
Ultra Low Phase Noise “Apollo” Series Oscillators, NVG45AD2025 and NVG45AD2140	KYOCERA AVX Components Corporation	Oven-controlled voltage-controlled crystal oscillators having extreme phase noise reduction	Seek a CCATS	12/31/2025
Deep Guard, Model DG-S1-20, Part Number US10115	Ultrasea, Inc	Modular, non-lethal subsurface net interdiction system	CCL ECCN 8A620.e	1/5/2026
Diode Assemblies, Part Numbers SG6301 Rev. 1 and SG6302 Rev. 1	Corfin Holdings Inc. d/b/a Micross	Electronic components	USML Category XII(e)(1)	1/5/2026
Signal Hunter, Model SH-6000 Version 3.3.4, Part Number DL-SH06000-01	Regulus Global, LLC	Radiofrequency detection and analysis system	USML Category XI(a)(4)(i)	1/5/2026
High Mobility Multipurpose Wheeled Vehicle (HMMWV) Model M1038/M998, Part Number: 069574	AM General	Specific unarmored 4-wheel drive military vehicle	CCL ECCN 0A606.a	1/5/2026
Inert Guided Projectile Prototype (Non-lethal), v1.0	James E. Smith LLC	Non-lethal projectile used in research and development	Seek a CCATS	1/5/2026
Mounting Bracket, Model 3068A, Part Number 00788	Truck-Lite Co., LLC	Mounting bracket for ground vehicle lights	CCL ECCN 0A606.x	1/5/2026
Signal Processor (P/N 7XX-3000-XXX SP), Receiver Transmitter (P/N 7XX-4000-XXX RT)	Griffon Corporation, d/b/a Telephonics Corporation	Line Replaceable Units for a Radar System	Signal Processor: USML Category XI(a)(5)(ii) when incorporating USG IFF Mode 4 or 5; otherwise, USML Category XI(a)(5)(i) Receiver Transmitter without firmware: ECCN 3A611.x Receiver Transmitter firmware: USML Category XI(d)	1/5/2026
Drone Delivery System, Version Number:1	Discordant Technologies LLC	Guidance kit for items dropped from an aircraft, that has not been designed for a specific payload, platform, or target	Seek a CCATS	1/5/2026
Drill with Polycrystalline Diamond (PCD) Edge and Tungsten Carbide Body, Part Numbers 55DR13NX-090699 N1DU, 84UM-0635-72-30, 84UM-0850-81-30, VI17200698-1910R.0 CD10, VIT7200698-.251R.0 CD10, VIT7200698-3135R.0 CD10, and VUK84U-0253-6.95R.0; Piloted Countersink with PCD Edge and Tungsten Carbide Body, Part Numbers VIT2OU0794-.188R.0, VIT20U0795-.248R.0, VIT20U0796-.310R.0, and VIT20U0797-373R.0; and Drill and Countersink with PCD Edge and Tungsten Carbide Body, Part Numbers	Sandvik Machining Solutions USA LLC	Cutting tools used to drill holes in aircraft components	Seek a CCATS	1/15/2026
BOS Thermal Imaging Sighting System, Model V1, Part Number BO-1	CHRK-Bishkek LLC	Device for observation, targeting, and fire-control assistance on heavy-caliber machine guns and vehicle-mounted weapon stations	USML Category XII(c)(2)(iii)	1/15/2026
EOTECH On Gun Laser (Non-Functioning/Disabled Unit), Model Number: OGL (Non-Functioning), Part Number: OGL-S-T-NF	Project Echo Holdings, LLC DBA: EOTECH, LLC	EOTECH On Gun Laser (OGL) housing	Seek a CCATS	1/20/2026
Specialized Rigid Wall Shelter System for Firing Container Unit (FCU), Part Number HMO10000B-E705	Marvin Engineering Co., Inc.	Portable shelter for a firing container unit	USML Category XVIII(e)	1/27/2026
Torren Software, Model Number: 0.1.3	Strategic Resilience Group, LLC	User interface and Large Language Model (LLM)-supported assessment of the ability to influence specific groups based on well-defined objectives	USML Category XI(b)	1/27/2026
SLM-5650 Satellite Modems with DSSS Firmware, Models A, B, and C, Part Numbers SLM-5650A/B/C	Comtech Telecommunications Corp	Devices that establish data links between satellites and other platforms	USML Category XI(a)(5)(iii)	1/27/2026
Miniaturized Laser Rangefinder Receiver with Range Processor, Model and Part Number 7551A-04	Analog Modules, Inc., a HEICO company	A laser rangefinding receiver	USML Category XI(c)(2)	1/27/2026
Rocket Engine Design Tool for Optimal Performance – REDTOP, v1.2.0, Part Number: RT-SU-1X_C	SpaceWorks Enterprises, Inc.	Software tool for conceptual-level design and analysis of liquid propellant rocket engines, excluding configuration data for modeling any specific engine	Seek a CCATS	1/27/2026
Charge Delivery System (CDS), Model 1, Version 1, Part Number 114000	TETAC Incorporated	Naval mine disposal and detonation system	USML Category VI(f)(8)	1/27/2026
VANQUISH-1C, Model Number: 00101800A	Chaos Industries, Inc.	Lightweight radar for the detection and tracking of airborne objects	Seek a CCATS	1/27/2026

 

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Notifications to the Congress of Proposed Commercial Export Licenses

 

February 17, 2026: 91 Fed. Reg 7351: February 17, 2026, the Directorate of Defense Trade Controls and the Department of State submitted to Congress 49 notices of Notifications of Proposed Commercial Export Licenses.

https://www.federalregister.gov/documents/2026/02/17/2026-03051/bureau-of-political-military-affairs-directorate-of-defense-trade-controls-notifications-to-the

 

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DDTC Frequently Asked Questions (FAQs)

 

Q: How do I submit classified information to the Directorate of Defense Trade Controls (DDTC), such as supporting classified information for a DSP-85?

 

A: Classified information can only be submitted to DDTC in a hard-copy document (i.e., paper) format, pursuant to the information provided below.

To submit classified documents to DDTC, please refer to the National Industrial Security Program Operating Manual (NISPOM)*, Chapter 5 (Safeguarding Classified Information), Section 4 (Transmission, starting on page 5-4-1) for detailed instructions.  The NISPOM can be accessed at this link:
https://www.federalregister.gov/documents/2020/12/21/2020-27698/national-industrial-security-program-operating-manual-nispom

 

The Defense Counterintelligence and Security Agency (DCSCA) will release an Industrial Security Letters (ISLs) that provides further guidance about the rule’s implementation and interim or supplemental information.  Each company’s Facility Security Officer (FSO) is the responsible party at the company to ensure compliance with the NISPOM and all ISLs.  As such, they should be aware of the requirements in the ISL.  ISLs can be accessed at https://www.dcsa.mil/Industrial-Security/National-Industrial-Security-Program-Oversight/NISP-Tools-Resources/.

 

Based on DDTC’s experience in receiving classified information through regular mail, DDTC recommends the following steps to ensure the security and delivery of your information:

• Consider using the US Postal Service Registered Mail service. This ensures a signature will be required for receipt of the delivery, as other carriers have dropped this requirement due to COVID-19 precautions.
• Only write the address below on the outer envelope. If the submission needs to be directed to a specific department or officer, add ‘Attention Of:’ on the INNER envelope.
• Address all submissions to the following:

Directorate of Defense Trade Controls

2401 E Street, NW

Suite H1200

Washington, DC 20522-0112

 

Please note that DDTC has not resumed acceptance of hand-delivered documents.

Contact DDTC Prior to Sending Classified Information:  Please contact Rob White at 202-663-1929 or WhiteRC3@state.gov to notify DDTC that you intend to send classified information.

*Please note there is a 2021 update to the NISPOM that modifies certain rules and incorporates the NISPOM into the Code of Federal Regulations.  We do not anticipate these changes will impact the information provided in this posting.  A summary of the 2021 NISPOM changes is available at this link: https://www.dcsa.mil/About-Us/News/News-Display/Article/2516880/32-code-of-federal-regulation-part-117-nispom-is-now-in-effect-cleared-contract/.  Additionally, DCSA offers a 32 CFR Part 117 NISPOM Rule Cross Reference Tool under the heading, “Key Resources for FSOs,” located at https://www.cdse.edu/Training/Toolkits/FSO-Toolkit/.

 

Q: We need to review a classified proviso for an important meeting next week. Can we send someone to DDTC to pick it up?

 

A: Yes, it is possible to pick up a classified proviso for your company at DDTC, but three factors must be met first.

• Company Clearance in NISS: DDTC must check the National Industrial Security System (NISS) and confirm your company meets all requirements for receiving and storing classified materials.
• Urgent Need: The company must have an urgent, time-sensitive need for the proviso. Otherwise, DDTC will send the proviso through its standard delivery method, which is the U.S. Postal Service (USPS). If you find USPS is too slow, we offer service through UPS Next Day, but only if you have a cleared street address in NISS.
• Cleared Company Representative:  Before setting the date or time for the in-person transfer, DDTC must submit information to the Department’s Bureau of Diplomatic Security (DS) to clear the company representative who is retrieving the proviso. The turnaround time for this clearance is about 24 hours.  To clear an individual, we need the following information:

 

• • Full name, and
  • Social Security Number.

 

To provide DDTC with information on the factors listed above, please contact Rob White whiterc2@state.gov and Ayanna Peoples peoplesad@state.gov.  Your company’s Facility Security Officer should be included on the cc line of all written communications.

 

Once the three factors are met, Rob or Ayanna can arrange a meeting with the Cleared Company Representative to transfer the classified proviso.  Please note the Cleared Company representative must bring two items to DDTC in order to receive a classified proviso:

• government photo identification card, and
• appropriate carrying case for classified documents.

 

Q: Can the § 126.7 exemption be used for transfers involving classified defense articles and defense services?

 

A: Yes.  However, consistent with the note to paragraph (b) in § 126.7, compliance with all separate security controls governing the handling of classified articles and services is still separately required.

 

 

Q: If I have classified information to provide in support of my CJ request, how should I submit that to the Department?

 

A: Classified information MAY NOT be submitted through the electronic system used to submit CJ requests. If you have classified information associated with your request, please so indicate in your online application form or cover letter. The analyst assigned to your case will contact you with options for relaying that information via proper channels.

 

Q: How do I export or obtain U.S. classified defense articles under the UK exemption?

 

A: You must obtain a written request, directive or contract from the U.S. Department of Defense prior to the initial export from the United States. After that, U.S. classified materiel (Confidential and above) eligible for transfer under the Treaty will be moved in accordance with the Treaty’s detailed arrangements and other applicable security requirements.

 

https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_faq_landing

 

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Department of Defense, Defense Security Cooperation Agency (DSCA)

 

DCSA Notifies Congress of Potential FMS Sale to Kingdom of Saudi Arabia

 

February 3, 2026: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Kingdom of Saudi Arabia has requested to buy F-15 Sustainment and related equipment. The potential sale includes the following non-major defense equipment items: spares and repair parts, consumables and accessories, and repair and return support; ground and personnel equipment; classified and unclassified software and software support; classified and unclassified publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $3.0 billion.

 

There will be various contractors associated with the provision of equipment and services involved with this case, and there is no prime contractor.

 

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4396586/kingdom-of-saudi-arabia-f-15-sustainment

 

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DCSA Notifies Congress of Potential FMS Sale to Iraq

 

February 5, 2026: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that Iraq has requested the extension of Contracted Logistical Services (CLS), including 24/7 help desk service, for two years in support of the Ministry of Interior’s VACIS XPL passenger vehicle scanning systems; corrective and preventive maintenance; spare and repair parts; software updates, remote monitoring; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $90 million.

 

The principal contractor will be Leidos, located in Reston, VA.

 

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4398638/iraq-contracted-logistical-services-for-vacis-xpl-passenger-vehicle-scanning-sy

 

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DCSA Notifies Congress of Potential FMS Sale to Ukraine

 

February 6, 2026 The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy Class IX spare parts in support of U.S. Army-supplied vehicles and weapon systems, as well as other related elements of logistics and program support. The estimated total cost is $185 million.

 

The principal contractor(s) will be determined from approved vendors.

 

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4399552/ukraine-class-ix-spare-parts

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The U.S. Department of State Notifies Congress of Potential FMS Sale to Jordan

February 26, 2026: The U.S. Department of State has made a determination approving a possible Foreign Military Sale to the Government of Jordan of Ku band multi-function radio frequency system (KuMRFS) radars and related equipment for an estimated cost of $280 million.  The State Department delivered the required certification notifying Congress of this possible sale.

 

The Government of Jordan has requested to buy KuMRFS radars and command and control system; generators; global positioning system receivers; spare and repair parts; special tools and test equipment; technical manuals and publications; training devices; new equipment training; U.S. Government and contractor technical, engineering, and logistics personnel services; concurrent spare parts, systems integration, and checkout support; field service representative support; contractor logistics support; program management reviews; and other related elements of logistics and program support.

 

The principal contractor will be RTX Missile Defense Technologies, located in Tucson, Arizona.

 

https://www.state.gov/jordan-ku-band-multi-function-radio-frequency-system-kumrfs-radars/

 

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Future Announcements Of Major Arms Sales

 

February 26, 2026: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) posted to their website that future announcement of major arms sales will be published on the U.S. Department of State’s website in accordance with Executive Order 14383 “ESTABLISHING AN AMERICA FIRST ARMS TRANSFER STRATEGY” signed on February 6, 2026.

 

https://www.state.gov/arms-sales-congressional-notifications/

 

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Department of Commerce – Bureau of Industry and Security (BIS)

 

Conforming Change to the Export Administration Regulations for Cambodia

 

February 4, 2026: 91 Fed. Reg. 5091: On February 4, 2026, BIS made conforming changes to the Export Administration Regulations (EAR) to reflect that Cambodia is no longer a Country Group D:5 country.

 

https://www.govinfo.gov/content/pkg/FR-2026-02-04/pdf/2026-02262.pdf

 

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Exports of U.S.-Origin Gas and Petroleum Products to Cuba

 

February 24, 2026: On February 24, 2026, the Department of Commerce, Bureau of Industry and Security (BIS) published on their website updated guidance on the availability of EAR License Exception Support for the Cuban People (SCP) for exports and reexports of U.S.-origin gas and other petroleum products to eligible Cuban private sector entities and to individual Cuban consumers. Under this guidance, certain transactions meeting the terms of License Exception SCP may be authorized without a license, including exports for private sector economic activities and those sold directly to individuals for personal or family use. License applications involving U.S.-origin gas and petroleum products that otherwise qualify for SCP, will be returned without action with direction to use the license exception. Exporters are responsible for ensuring that all SCP conditions are met and should carefully review § 740.21 before proceeding.

 

As a reminder, exporters and reexporters are responsible for complying with all applicable regulatory requirements in particular the Department of Treasury’s Office of Foreign Assets Control (OFAC) Cuba-related sanctions.

 

https://www.bis.gov/media/documents/scp-gas-petroleum-faq.pdf and

https://www.bis.gov/licensing/country-guidance/cuba-export-controls

 

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Office of Foreign Assets Control (OFAC)

 

Launch of Voluntary Self-Disclosure Portal

 

February 6, 2026: OFAC launched a new online Voluntary Self-Disclosure Portal. This portal provides a streamlined, secure method for submitting voluntary self-disclosures of potential violations of OFAC-administered sanctions programs.

 

https://disclosure.ofac.treas.gov/

 

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Office of Foreign Assets Control Reporting, Procedures and Penalties Regulations Sanctions Reconsideration Portal

 

February 26, 2026: OFAC is seeking to add a new electronic Sanctions Reconsideration Portal information collection contained within § 501.807 of OFAC’s Reporting, Procedures and Penalties Regulations (the ‘‘Regulations’’), which pertains to the operation of the various economic sanctions programs administered by OFAC under 31 CFR chapter V. The electronic Sanctions Reconsideration Portal would gather specific information from the petitioner and provide a more efficient process for collecting and reviewing applications for reconsideration. Petitioner use of the Sanctions Reconsideration Portal will be voluntary.  The submissions covered by this information collection will be reviewed by the U.S. Department of the Treasury and may be used for sanctions reconsiderations and other regulatory or administrative actions by OFAC under its authorities.

 

The public is invited to submit comments to OFAC related to the information collection portal. Written comments must be received by March 27, 2026 to be assured of consideration.

 

https://www.govinfo.gov/content/pkg/FR-2026-02-25/pdf/2026-03780.pdf

 

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U.S. Census Bureau

 

Update to the Automated Export System Trade Interface Requirements (AESTIR) Appendix O – DDTC ITAR Codes

 

February 18, 2026:

AESTIR Appendix O has been updated to include International Traffic in Arms Regulations (ITAR) Exemption Code 126.9U – Temporary export, reexport, or temporary import of vessels described in USML Category XX(a)(10).

Additional information about the ITAR exemption can be found:

• https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.federalregister.gov%2Fdocuments%2F2025%2F08%2F27%2F2025-16382%2Finternational-traffic-in-arms-regulations-us-munitions-list-targeted-revisions%3Futm_campaign=%26utm_content=%26utm_medium=email%26utm_source=govdelivery/1/0100019c721347d0-c14be6aa-ee0c-40ba-aacb-4d2476654091-000000/jl2rMIbrzGwNzuWYJXgjnPhDFXsZ75wd-vZgSWqgMc8=445
• https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.pmddtc.state.gov%2Fddtc_public%3Fid=ddtc_search%26q=underwater%2Buncrewed%2Bvessels%26utm_campaign=%26utm_content=%26utm_medium=email%26utm_source=govdelivery/1/0100019c721347d0-c14be6aa-ee0c-40ba-aacb-4d2476654091-000000/1trUUUOY88PZFVhNCqj4kH0VV9TDXnMquCvUC8URNII=445

 

Fact sheet can be found at:

• https://links1.govdelivery.com/CL0/https:%2F%2Fcontent.govdelivery.com%2Fattachments%2FUSCENSUS%2F2026%2F02%2F18%2Ffile_attachments%2F3557556%2FFact%2520Sheet%2520-%2520LR1%2520-%252020250827.pdf/1/0100019c721347d0-c14be6aa-ee0c-40ba-aacb-4d2476654091-000000/68lg_uzeh1oygTcJvoUXUQq4_jVvzK1d6BJPC2shsuI=445

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How to Resolve Common AES Response Messages

 

February 19, 2026:

 

When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning.  It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations.

To help you take the appropriate action, here is guidance on how to address one of the most frequent Response Messages that were generated in the AES for the previous month.

Response Code:  643

Narrative:         Quantity (2) Must Be Greater Than Zero

Severity:           Fatal

Reason:            The Schedule B/HTS number reported requires a second Quantity to be reported and the Quantity (2) is missing or reported as zero.

Resolution:      Quantity (2) must be greater than zero.

Verify the Quantity (2) reported, correct the shipment and resubmit.

For a complete list of the AES Response Codes, their reasons and resolutions, see:

Appendix A – Commodity Filing Response Messages.

 

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License Type Code Requirements

 

February 26, 2026:

The U.S. Census Bureau was notified by the Bureau of Industry and Security (BIS) about an increase in filers reporting License Type Code “C33” for shipments with Drug Enforcement Administration (DEA) permit information.  DEA along with several other Partnering Government Agencies (PGA) have their own record sets for the collection of permit and license information. However, DEA and other PGAs that collect permit and license information through PGA Record Sets do not have their own License Type Codes.  For consistency, any agency that does not have their own License Type Code should report  “Other Partnership Agency License” or “OPA” in the License Type Code.

Please note, BIS, Department of State, Office of Foreign Assets Control, Nuclear Regulatory Commission, and Department of Energy (covered under E01) licenses cannot use License Type Code “OPA.”   Those licenses must be reported under the specific agency’s License Type Code. Please refer to Appendix F for the appropriate License Type Code selection for your shipment and Appendix Q for the existing PGA Record Sets. For more information or questions pertaining to your permit or license, please refer to the appropriate licensing agency.

 

LATEST SANCTIONS FINES & PENALTIES

 

This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.

 

Fines and Penalties

 

February 6, 2026. The U.S. District Court of Arizona sentenced Peter Biar Ajak to 46 months in prison, followed by three years of supervised release. Abraham Chol Keech, Ajak’s co-defendant, was sentenced on December 18, 2025 to 41 months in prison and three years of supervised release. Both previously plead guilty to conspiracy to violate the Arms Export Control Act (AECA) and the Export Control Reform Act (ECRA).

 

The defendants, with Mr. Ajak directing the conspiracy, amassed $4M military-grade weapons – which included ten Stinger missile systems, two hundred grenade launchers, more than a thousand machine guns and rifles, and over 3.5 million rounds of ammunition – to effect a coup d’état in South Sudan. Furthermore, the individuals sought to export the weapons to South Sudan without the required export licenses.

 

https://www.justice.gov/opa/pr/two-defendants-sentenced-prison-conspiring-illegally-export-weapons-south-sudan

 

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February 11, 2026: Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement agreement with Applied Materials Inc. of Santa Clara, California (AMAT) and Applied Materials Korea, Ltd. (AMK), covering illegal exports of U.S. semiconductor manufacturing equipment to China. AMAT and AMK agreed to pay a penalty of approximately $252 million – the second-highest penalty ever imposed by BIS.

 

bis.gov/press-release/applied-materials-pay-252-million-penalty-bis-illegally-exporting-semiconductor-manufacturing-equipment

 

See our article “BIS imposes $252.5 Million Penalty on Applied Materials and Korean Subsidiary over unauthorized Reexports to SMIC” on our website or found at the attached Link

 

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February 12, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $1,720,000 settlement with IMG Academy, LLC to settle its potential civil liability for 89 apparent violations of OFAC counternarcotics sanctions. Between 2019 and 2025, IMG Academy dealt in the property or interests in property of two Specially Designated Nationals (SDNs) sanctioned for their ties to a sanctioned Mexico-based drug cartel. Specifically, IMG Academy entered into yearly tuition agreements with the SDNs and received and processed payments pursuant to those agreements. The settlement amount reflects OFAC’s determination that IMG Academy’s conduct was non-egregious and not voluntarily disclosed.

 

https://ofac.treasury.gov/media/935006/download?inline

 

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February 13, 2026: Eleview International Inc. (Eleview), Oleg Nayandin (Mr. Nayadin), 54, of Fairfax, Virginia, and Vitaliy Borisenko (Mr. Borisenko), 39, of Vienna, Virginia, were sentenced on February 13, 2026 for conspiracy to violate the Export Control Reform Act. Eleview was ordered to pay a fine of $125,000 and sentenced to three years of probation that included requirements to submit biannual compliance reports and mandate export-control training for its employees. Mr. Nayandin was sentenced to three years in prison. Mr. Borisenko was sentenced to a year in prison.

 

Eleview, Mr. Nayandin, and Mr. Borisenko operated an e-commerce website that allowed Russian customers to order U.S. goods and technology directly from U.S. retailers, who shipped the items to Eleview’s warehouse in Chantilly. They then consolidated the packages before shipping them to the Russian customers, often using other freight forwarders as intermediaries. After the Department of Commerce imposed stricter export controls in response to Russia’s further invasion of Ukraine in February 2022, Mr. Nayandin and Mr. Borisenko, on behalf of Eleview, coordinated shipments of items to purported end users in Turkey, Finland, and Kazakhstan that were ultimately destined for end users in Russia. To facilitate these illegal exports, they made numerous false statements to other freight forwarders about the end users and ultimate consignees of the items in these shipments.

 

https://www.justice.gov/usao-edva/pr/virginia-company-owner-and-senior-employee-sentenced-illegally-exporting-millions

 

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February 18, 2026: The Justice Department announced that Milan Dimitrov, a Bulgarian national, was sentenced in federal court to 38 months, time served, for conspiracy to violate the International Emergency Economic Powers by facilitating the export of U.S.-origin radiation-hardened and high-temperature electronic circuits to Russia.

 

In 2014, following Russia’s invasion of Crimea, the U.S. imposed export controls that made it illegal to export those goods directly to Russia without a license from the Department of Commerce, Bureau of Industry and Security.

 

Mr. Dimitrov worked at Multi Technology Integration Group EOOD (MTIG), a Bulgarian company created to enable two Russian companies to acquire U.S.-origin radiation-hardened and high-temperature electronic circuits.  In 2015, MTIG shipped U.S.-origin radiation-hardened and high-temperature electronic circuits to OOO Sovtest Comp in Russia in violation of the EAR and IEEPA.
https://www.justice.gov/usao-wdtx/pr/bulgarian-national-sentenced-austin-scheme-illegally-export-us-origin-sensitive

 

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February 24, 2026:   The Justice Department announced that Peter Williams (Mr. Williams), 39, an Australian national, was sentenced in the U.S. District Court for the District of Columbia to 87 months in prison for selling his employer’s trade secrets — sensitive and protected cyber-exploit components — to a Russian cyber-tools broker, announced the Department of Justice. In addition to the 87-month prison term, U.S. District Court Judge AliKhan for the District of Columbia ordered Mr. Williams to serve three years of supervised release with special conditions, to forfeit a money judgment of $1.3 million, cryptocurrency and property to include a house, and luxury items such as watches and jewelry.

“Peter Williams stole a U.S. defense contractor’s trade secrets about highly sensitive cyber capabilities and sold them to a broker whose clients include the Russian government, putting our national security and countless potential victims at risk,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division.

 

Both the Department of State and the Department of Treasury’s Office Of Foreign Assets Control took separate action on February 24, 2026 to disrupt a Russian cyber-tools broker and its operators.

 

https://www.justice.gov/opa/pr/former-general-manager-us-defense-contractor-sentenced-87-months-selling-stolen-trade

 

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February 25, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that a natural U.S. person (“U.S. Person-1”) has agreed to pay $3,777,000 to settle their potential civil liability for 20 apparent violations of OFAC sanctions on Syria previously in effect. Between January 2018 and December 2021, when U.S. sanctions on Syria were in place, U.S. Person-1 provided managerial services to Syrian entities in their role as an executive and board member for four Syrian real estate companies. These services included reviewing and signing financial statements, approving operational and employee expenses, and supervising the collection of service fees. The apparent violations occurred under the former regime of Syrian president Bashar al-Assad, and prior to the removal of U.S. sanctions on Syria in 2025.

 

The settlement amount reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were egregious. This enforcement action highlights the obligations of all U.S. persons, including U.S. citizens residing outside of the United States, to comply with OFAC sanctions.

 

https://ofac.treasury.gov/recent-actions/20260225_66

 

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February 25, 2026: The Bureau of Industry & Security published an administrative enforcement settlement with Vizocom ICT (Vizocom) of El Cajon, CA for one violation of the EAR.

 

On or about May 22, 2019, Vizocom uploaded/transferred specifications for a U.S. manufacturer’s Very High Frequency/Ultra High Frequency (VHF/UHF) antenna to the “Made in China” portal operated by a Chinese manufacturer located in the People’s Republic of China (“PRC”). The antenna is designed for military radios and has no civilian applications.  The specification is classified as under Export Control Classification Number (“ECCN”) 3E611 for the production of an antenna controlled under ECCN 3A611. Pursuant to §§ 742.4 and 742.6 of the EAR, a BIS license was required to export the specifications to the PRC, and no license exceptions were available. Vizocom did not seek or obtain a license for the export of the specifications. Vizocom purchased antennas from the Chinese manufacturer that were produced based on the specifications that were uploaded and transmitted to the Chinese manufacturer. Vizocom supplied 450 antennas produced by the Chinese manufacturer to the U.S. Navy, falsely labeling the packaging an specification sheet to hide the identity of the manufacturer. Vizocom received $165,109.50 for the antennas.

 

The BIS assessed against Vizocom a civil penalty in the amount of $374,474.  In addition to the civil penalty, Vizocom is subject to a five-year denial of its export privileges under EAR.

 

https://www.bis.gov/media/documents/vizocom-ict-final-order-2-24-2026.pdf

See our article “BIS Settlement with Vizocom ICT Highlights Enforcement Focus on Technical Data

Transfers in Vendor Workflows” at the attached Link

 

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February 25, 2026: Former U.S. Air Force officer and pilot Gerald Eddie Brown, Jr. (Mr. Brown), also known by the call sign “Runner,” 65, a U.S. citizen, was arrested on February 25, 2026 in Jeffersonville, Indiana. Brown was charged by criminal complaint for providing and conspiring to provide defense services to Chinese military pilots without authorization, in violation of the Arms Export Control Act (AECA).

 

Brown in or around August 2023 began to arrange the terms of his contract to train Chinese military pilots, using a co-conspirator to negotiate with Stephen Su Bin, a Chinese national who in 2016 pled guilty in the U.S. District Court for the Central District of California to conspiring to hack into the computer networks of major U.S. defense contractors and steal sensitive military and export-controlled data for the PRC. He was sentenced to nearly four years in prison. Su Bin and his company PRC Lode Technology Company were also added to the U.S. Department of Commerce’s Entity List in 2014.  Throughout these communications, Brown consistently stated his intent to train PRC military pilots in combat aircraft operations.

 

In December 2023, Brown traveled to China to begin his work training PRC military pilots.

 

https://www.justice.gov/opa/pr/former-us-air-force-pilot-arrested-providing-defense-services-chinese-military

 

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February 26, 2026: The Bureau of Industry & Security (BIS) published on February 26, 2026 an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates, FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems Inc, collectively referred to as Teledyne FLIR.  BIS assessed against Teledyne FLIR a civil penalty of $1M for 19 violations of the EAR.

 

The violations are the result of the following:

• A flawed de minimis calculations that led Teledyne FLIR to incorrectly conclude that foreign produced commodities containing U.S. controlled content was not subject to the EAR causing the exports without the required BIS export license of 6A003 camera cores and 6A003.b.4.b camera kits from Sweden to China.
• The intent to evade the EAR by entering into an agreement with a Chinese drone manufacturer to integrate a 6A003.b.4.b FLIR camera into a European-made camera system. The agreement was structed to purposely push the value of the U.S. controlled content to 25% below fair market value.
• Failure to comply with the recordkeeping requirements imposed as conditions of a BIS export license.
• Failure to obtain BIS export license for export transactions involving an address, ADDRESS 04, identified on the Entity List.

 

https://www.bis.gov/media/documents/teledyne-flir-final-order-2-26-2026.pdf

 

Sanctions

 

Department of the Treasury, Office of Foreign Assets Control (OFAC)

 

February 2, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 5U, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026.

 

General License No. 5U Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026

All transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond that would be prohibited by subsection l(a)(iii) of Executive Order (E.O.) 13835 of May 21, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized.

 

This general license does not authorize any transactions or activities otherwise prohibited by the VSR, or any other part of 31 CFR chapter V.

 

Additionally, OFAC also issued amended Venezuela-related Frequently Asked Question (FAQ 595).

 

Question 595: What does Venezuela-related General License 5U authorize?

 

Answer: The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5U on February 2, 2026, which further delays the effectiveness of the authorization in GL 5 until March 20, 2026. Between October 24, 2019 and March 20, 2026 (the date the authorization in General License 5U becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

https://ofac.treasury.gov/recent-actions/20260202

https://ofac.treasury.gov/media/934976/download?inline

https://ofac.treasury.gov/faqs/595

 

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February 6, 2026:  OFAC issued 10 Venezuela-related FAQs 1226 – 1235

Question 1235: Does Venezuela General License (GL) 46 authorize downstream trading activities in Venezuelan-origin oil?

 

Answer: Yes. Once a transaction with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or its majority-owned subsidiaries (PdVSA Entities) has been completed pursuant to GL 46, and the interest—including any future or contingent interest—of a blocked entity is fully extinguished, then the oil can be freely sold, resold, and traded by any downstream purchaser, including entities that are not established U.S. entities, as defined in GL 46.

 

Question 1234: How does a financial institution verify a transaction is compliant with Venezuela General License (GL) 46?

 

Answer: In connection with its normal due diligence, a financial institution may rely on the statements of its customer that the transaction is consistent with the terms of GL 46, unless it knows or has reason to know otherwise.

Question 1233: Are all entities engaged in a transaction authorized by Venezuela General License (GL) 46 required to have contracts with the dispute resolution requirement included in paragraph (a)(1)?

 

Answer: No. The dispute resolution requirement in paragraph (a)(1) of GL 46 applies only to contracts governing transactions undertaken by an established U.S. entity when the contract is with the Government of Venezuela (GOV), Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (PdVSA Entities).

 

This requirement does not apply to indirect parties or indirect counterparties involved in transactions authorized by GL 46, such as downstream transactions involving the provision of shipping, insurance, or other services to an entity engaged in a transaction involving PdVSA. For example, this provision would not apply to a contract between an insurance provider and an established U.S. entity engaged in a transaction with PdVSA to purchase Venezuelan-origin oil (though it would apply to the contract between the U.S. entity and PdVSA).

 

Question 1232. What does OFAC consider “commercially reasonable terms,” as described in Venezuela General License (GL) 46?

 

Answer: “Commercially reasonable terms” means terms that are consistent with prevailing market and industry standards for like or similar products produced by a company of similar size and scope, while taking into account characteristics such as quality, quantity, pricing, performance, and safety, among others. Commercially reasonable terms include terms related to, among other things, the governance, economics, operations, and legal/compliance requirements of a contract negotiated at arm’s length between two or more parties.

 

Question 1231: What entities or jurisdictions are excluded from transactions authorized under Venezuela General License (GL) 46?

 

Answer: GL 46 excludes the involvement of persons located in or organized under the laws of the Russia Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, and the Republic of Cuba—as well as any entity owned or controlled, directly or indirectly (including by or in a joint venture with) any of the foregoing.

 

In addition, GL 46 does not authorize transactions with any Venezuelan or U.S. entity that is owned or controlled by, or in a joint venture with, a person located in or organized under the laws of the People’s Republic of China. However, GL 46 does not restrict the resale of Venezuelan-origin oil to China by an established U.S. entity.

 

Question 1230: Can an entity that is not an “established U.S. entity” be involved in transactions authorized by Venezuela General License (GL) 46?

 

Answer: Yes. Non-U.S. persons may engage in transactions or provide services that are ordinarily incident and necessary to the established U.S. entity’s transactions authorized by GL 46. Such activities or ancillary services could include: providing transportation and logistics services to an established U.S. entity for the export of Venezuelan-origin oil; providing marine insurance to vessels chartered by established U.S. entities to transport Venezuelan-origin oil; the financing of related cargoes or receivables; leasing storage facilities for Venezuelan-origin oil purchased by an established U.S. entity; or contracting with established U.S. entities for repair or maintenance services of infrastructure necessary to effectuate the export of oil from Venezuela, among others.

Please see FAQ 1235 for additional information regarding authorized downstream trading activities.

Please see FAQ 1231 for certain individuals and jurisdictions excluded from the scope of GL 46.

 

Question 1229: Venezuela General License (GL) 46 authorizes certain activity by an “established U.S. entity.” What is an “established U.S. entity” for purposes of GL 46?

 

Answer: For purposes of GL 46, the term “established U.S. entity” means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.

GL 46 is designed to help ensure that the oil exported from Venezuela will be through legitimate and authorized channels, consistent with U.S. law and President Trump’s efforts to restore prosperity, safety, and security to the United States and Venezuela. Established U.S. companies should be familiar with complying with U.S. laws and regulations, including U.S. sanctions regulations, which will help ensure their ability to market Venezuelan oil in the global marketplace for the benefit of the United States, Venezuela, and our allies.

 

Question 1228: Does Venezuela General License (GL) 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil,” authorize exploration activity or negotiations for new investment activities?

 

Answer: No. GL 46 authorizes the purchase, exportation, and sale of Venezuelan-origin oil that has already been extracted, including the refining of such oil. It does not authorize other exploration or production activities, such as conducting geological surveys, drilling wells, or extracting oil from fields in Venezuela, nor does it authorize activities related to investment in the Venezuelan oil sector, such as negotiations with Petróleos de Venezuela, S.A. (PdVSA) to enter into a contract to develop or operate oil fields, blocks, or other concessions. For more information on what transactions are authorized by GL 46, see FAQ 1227.

 

Questions 1227: What activities does Venezuela General License (GL) 46 authorize?

 

Answer: GL 46 authorizes activities that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil by an established U.S. entity, which may include:

• engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
• conducting safety, environmental, and other relevant inspections, including site surveys;
• arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
• conducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
• coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
• making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
• the financing of related cargos or receivables.

 

Notably, GL 46 does not authorize:

• transactions that are not on commercially reasonable terms;
• payment in gold or the use of debt swaps;
• payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
• any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
• transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
• the unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations; or
• any transaction involving a blocked vessel.

 

For information on how an entity that is not an “established U.S. entities” (including non-U.S. entities) can be involved in transactions authorized by GL 46, see FAQ 1230.

 

Question 1226: Does “Venezuelan-origin oil” as referenced in Venezuela General License (GL) 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil,” include petroleum products?

 

Answer: Yes. Consistent with the term “Venezuelan oil” as defined in section 5(a) of Executive Order 14245, “Imposing Tariffs on Countries Importing Venezuelan Oil,” the term “Venezuelan-origin oil” means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.

As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. In keeping with the EIA’s standard definition, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.

 

Accordingly, crude oil blends such as Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke, are considered “Venezuelan-origin oil” for the purposes of GL 46.

 

https://ofac.treasury.gov/faqs/added/2026-02-06

https://www.federalregister.gov/documents/2025/03/27/2025-05440/imposing-tariffs-on-countries-importing-venezuelan-oil

https://ofac.treasury.gov/media/934886/download?inline

https://ofac.treasury.gov/media/934886/download?inline

 

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February 6, 2026: The Department of State sanctioned 15 entities, two individuals, and 14 shadow fleet vessels connected to the illicit trade in Iranian petroleum, petroleum products, and petrochemical products. These targets have generated revenue that the regime uses to conduct its malign activities. Based on the Department of State’s sanctions, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) added the following individuals to OFAC’s SDN List in connection to the illicit trade in Iranian petroleum, petroleum products, and petrochemical products:

 

• Ozsuren, Mehmet of the United Kingdom; and
• Shinde, Akash Anant of India;

 

The following entities have also been added to OFAC’s SDN List:

 

• All Win Shipping Management Limited of Hong Kong;
• Amon Kimya Ve Makina Sanayi Ve Ticaret Limited Sirketi of Turkey;
• Bakht Al Azhar Trading L.L.C of U.A.E.;
• Diako Ic Ve Dis Ticaret Anonim Sirketi of Turkey;
• Elevate Marine Management Private Limited of India;
• Elysian Horizon Corp of the Seychelles;
• Fluxus Marine Inc of Kazakhstan;
• Manarat Alkhaleej Marine Services FZE of the U.A.E.;
• Mars Oceanway Inc of Turkey;
• MHK Shipping Corp of Turkey;
• Mphasis Marine Solutions FZE of the U.A.E.;
• Qingdao Ocean Kimo Ship Management Co Ltd of China;
• Shanghai Qizhang Ship Management Co., Ltd of China;
• Starex Dis Ticaret Kimya Anonim Sirketi of Turkey; and
• Vicens Marine Co of the Marshall Islands.

 

The following vessels have been added to OFAC’s SDN List:

 

• Al Safa (3E3958) Oil Products Tanker Panama flag; Vessel Registration Identification IMO 9222649;
• Aqua Live (P4AE06) Crude Oil Tanker Aruba flag; Vessel Registration Identification IMO 9282792;
• Benedict (TJMC128) Crude Oil Tanker Cameroon flag; Vessel Registration Identification IMO 9293155;
• Benlai (8PQJ) Crude Oil Tanker Barbados flag; Vessel Registration Identification IMO 9312494;
• Fortune Gas (3E2335) LPG Tanker Panama flag; Vessel Registration Identification IMO 9471123;
• Gas River (3E2285) LPG Tanker Panama flag; Vessel Registration Identification IMO 9369760;
• Gaz Crystal (3E5206) LPG Tanker Panama flag; Vessel Registration Identification IMO 9318618;
• Ocean Guardian (3E5421) Oil Products Tanker Panama flag; Vessel Registration Identification IMO 9267948;
• Rayyan Gas (T8A4711) LPG Tanker Palau flag; Vessel Registration Identification IMO 9133109;
• Veter (TJMC657) Crude Oil Tanker Cameroon flag; Vessel Registration Identification IMO 9233739;
• Vicscene (a.k.a. GLOBAL HARVEST) (8PAA6) Crude Oil Tanker Barbados flag; Vessel Registration Identification IMO 9290775;
• White Shark (T7DB9) LPG Tanker San Marino flag; Vessel Registration Identification IMO 9155626;
• Yongheng Ocean (8PZW8) Chemical/Oil Tanker Barbados flag; Vessel Registration Identification IMO 9234472; and
• Zevs (TJMC822) Crude Oil Tanker Cameroon flag; Vessel Registration Identification IMO 9168946.

 

https://ofac.treasury.gov/recent-actions/20260206 and

https://www.state.gov/releases/office-of-the-spokesperson/2026/02/sanctions-to-combat-illicit-traders-of-iranian-oil-and-the-shadow-fleet-2/

 

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February 10, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued:

Venezuela General License 48, “Authorizing the Supply of Certain Items and Services to Venezuela;”

Venezuela General License 30B, “Authorizing Certain Transactions Necessary to Port and Airport Operations;” and

Venezuela General License 46A, “Authorizing Certain Activities Involving Venezuelan-Origin Oil.

 

General License No. 48 Authorizing the Supply of Certain Items and Services to Venezuela

All transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), that are ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil or gas in Venezuela are authorized, provided that:

(1) Any contract for such transactions with the Government of Venezuela, PdVSA, or PdVSA Entities specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occur in the United States; and

(2) Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury.

 

This general license does not authorize:

(1) Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro; 2

(2) Any transaction involving a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the People’s Republic of China, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;

(3) The unblocking of any property blocked pursuant to the VSR;

(4) Any transaction involving a blocked vessel;

(5) The formation of new joint ventures or other entities in Venezuela to explore or produce oil or gas; or

(6) Any transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela.

Any person that exports, reexports, sells, resells, or supplies goods, technology, software, or services pursuant to this general license must provide a detailed report to Sanctions_inbox@state.gov and VZReporting@doe.gov for each of these transactions.

Reports are due ten days after the execution of the first of such transactions and every 90 days thereafter while such transactions are ongoing.

 

General License No. 30B Authorizing Certain Transactions Necessary to Port and Airport Operations

All transactions and activities involving the Government of Venezuela prohibited by Executive Order (E.O.) 13884 of August 5, 2019, as incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela are authorized.

 

All transactions and activities prohibited by E.O. 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the VSR, involving the Instituto Nacional de los Espacios Acuaticos (INEA), or any entity in which INEA owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela are authorized.

 

This general license does not authorize any transactions or activities otherwise prohibited by the VSR, or any other part of 31 CFR chapter V, or any transactions or activities with any blocked person other than INEA, or any entity in which INEA owns, directly or indirectly, a 50 percent or greater interest, or any Government of Venezuela person that is blocked solely pursuant to E.O. 13884, unless separately authorized.

General License No. 46A Authorizing Certain Activities Involving Venezuelan-Origin Oil

All transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil, including the refining of such oil, by an established U.S. entity are authorized, provided that:

(1) Any contract for such transactions with the Government of Venezuela, PdVSA, or PdVSA Entities specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occur in the United States; and

(2) Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury.

 

This general license does not authorize:

(1) Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on 2 behalf of the Government of Venezuela, including the petro;

(2) Any transaction involving a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;

(3) Any transaction involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;

(4) The unblocking of any property blocked pursuant to the VSR; or

(5) Any transaction involving a blocked vessel.

 

Any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil to countries other than the United States pursuant to this general license must provide a detailed report to Sanctions_inbox@state.gov and VZReporting@doe.gov for each of these transactions:

 

Reports are due ten days after the execution of the first of such transactions and every 90 days thereafter while such transactions are ongoing.

 

https://ofac.treasury.gov/recent-actions/20260210_33

https://ofac.treasury.gov/media/934986/download?inline

https://ofac.treasury.gov/media/934996/download?inline

https://ofac.treasury.gov/media/935001/download?inline

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February 10, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on Hizballah operatives who continue to exploit Lebanon’s informal financial sector that generate revenue for Hizballah. These actors have supported sanctions evasion schemes involving Hizballah-controlled financial institution Al-Qard Al-Hassan (AQAH) and an Iran-based Hizballah finance team operative. Hizballah uses AQAH as a financial institution to undermine the Lebanese state and fund its terrorist activities.

The following individuals have been added to OFAC’s SDN List:

 

• Borisov, Andrey Viktorovich or Russia; and
• Maged, Mohamed Nayef of Lebanon.

 

The following entities have been added to OFAC’s SDN List:

 

• Brilliance Maritime Ventures S.A of Panama;
• Jood Sarl (a.k.a. “JUD”) of Lebanon;
• Platinum Group International Dis Ticaret Limited Sirketi of Turkey; and
• Sea Surf Shipping Limited of Turkey.

 

The following vessels have been added to OFAC’s SDN List:

• Brilliance Bulk Carrier Panama flag; Vessel Registration Identification IMO 9450715; and
• Lara General Cargo St. Kitts & Nevis flag; Vessel Registration Identification IMO 9221475

 

https://ofac.treasury.gov/recent-actions/20260210 and

https://www.state.gov/releases/office-of-the-spokesperson/2026/02/sanctioning-hizballah-finance-operatives-2/

 

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February 13, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 49, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela;” and Venezuela-related General License 50, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities.

 

General License No. 49 Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela

All transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, that are related to the negotiation of and entry into contingent contracts for new investment in oil or gas sector operations in Venezuela are authorized, provided that the performance of any such contract is made expressly contingent upon separate authorization from the Office of Foreign Assets Control (“contingent contracts”).

 

This general license does not authorize:

(1) Any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the People’s Republic of China, or any entity that is owned or controlled by or in a joint venture with such persons;

(2) The unblocking of any property blocked pursuant to the VSR; or

(3) Any transaction involving a blocked vessel.

 

General License No. 50 Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities

All transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), that are related to oil or gas sector operations in Venezuela of the entities listed in the Annex to this general license and their subsidiaries are authorized, provided that:

(1) Any contract for such transactions with the Government of Venezuela, PdVSA, or PdVSA Entities specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occur in the United States; and

(2) Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury.

 

This general license does not authorize:

(1) Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;

(2) Any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the People’s Republic of China, or any entity that is owned or controlled by or in a joint venture with such persons;

(3) The unblocking of any property blocked pursuant to the VSR; or 2

(4) Any transaction involving a blocked vessel.

 

Any person that engages in transactions pursuant to this general license must provide a detailed report to Sanctions_inbox@state.gov and VZReporting@doe.gov.

 

Reports are due ten days after the execution of the first of such transactions and every 90 days thereafter while such transactions are ongoing.

 

https://ofac.treasury.gov/recent-actions/20260213

https://ofac.treasury.gov/media/935011/download?inline

https://ofac.treasury.gov/media/935016/download?inline

 

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February 18, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new Venezuela-related Frequently Asked Questions (FAQs 1236 and 1237).

 

Question 1236: How does Venezuela General License (GL) 30B differ from Venezuela GL 30A?

Top of Form

 

Bottom of Form

Answer: On February 10, 2026 OFAC issued Venezuela GL 30B, “Authorizing Certain Transactions Necessary to Port and Airport Operations,” which removes the prohibition in GL 30A regarding transactions or activities related to the exportation or reexportation of diluents to Venezuela.  Transactions authorized by GL 30B continue to include payments that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela, including transactions involving the Instituto Nacional de los Espacios Acuaticos (INEA) or its majority-owned subsidiaries.  GL 30B authorizes the payment of port fees and customs duties—including for activities authorized under Venezuela GLs 46A, 47, and 48.

 

Question 1237: Do Venezuela General Licenses (GLs) 46A and 48 allow for the payments of certain local taxes, permits, and fees in support of authorized transactions involving Venezuela’s oil or gas sectors?

Top of Form

Answer

Bottom of Form

: Yes.  Consistent with other authorizations issued by OFAC pursuant to the Venezuela Sanctions Regulations (VSR), GLs 46A and 48 authorize routine payments of local taxes, permits, and fees to the Government of Venezuela (GOV) or its instrumentalities.

However, other payments, including royalties, fixed per-barrel production levies, or federal taxes to blocked persons, such as the GOV or Petróleos de Venezuela, S.A. (PdVSA), must be made into the Foreign Government Deposit Funds, as specified in Executive Order (E.O.) 14373, or any other account as instructed by the U.S. Department of the Treasury.

 

https://ofac.treasury.gov/recent-actions/20260218

 

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February 19, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).  The action targets Kovay Gardens, a Mexican timeshare resort, as well as five Mexican individuals and 17 Mexican companies associated with the network.  Many of these individuals and entities are based in or near Puerto Vallarta, a popular tourist destination that also serves as a strategic stronghold for CJNG.  CJNG is a brutally violent terrorist cartel that continues to diversify its illicit revenue streams beyond drug trafficking, including through timeshare fraud and fuel theft.  These activities generate significant proceeds for the organization at the expense of U.S. citizen victims. Timeshare fraud often targets vulnerable older Americans and can defraud victims of their life savings.

 

https://home.treasury.gov/news/press-releases/sb0400

https://ofac.treasury.gov/media/935021/download?inline

 

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February 19, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Counter Terrorism General License 34, “Authorizing the Wind Down of Transactions Involving Kovay Gardens.” Kovay Gardens, a timeshare resort, was added to the SDN List as result of being controlled by the CJNG and for defrauding potential buyers and owners.

 

General License No. 34 Authorizing the Wind Down of Transactions Involving Kovay Gardens

All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR) or the Illicit Drug Trade Sanctions Regulations, 31 CFR part 599 (IDTSR), that are ordinarily incident and necessary to the wind down of any transaction involving Kovay Gardens, or any entity in which Kovay Gardens owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, March 21, 2026, provided that any payment to a blocked person is made into a blocked account in accordance with the IDTSR and GTSR.

 

This general license does not authorize any transactions otherwise prohibited by the GTSR or IDTSR, including transactions involving any person blocked pursuant to the GTSR or IDTSR other than the blocked persons described in this general license, unless separately authorized.

 

https://ofac.treasury.gov/recent-actions/20260219 https://ofac.treasury.gov/media/935026/download?inline

 

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February 19, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three commanders of the Rapid Support Forces (RSF)—a Sudanese paramilitary group—for their actions in El-Fasher, Sudan.  These individuals were involved in the RSF’s 18-month siege of and eventual capture of El-Fasher, in which the RSF perpetrated a horrific campaign of ethnic killings, torture, starvation, and sexual violence.  Since the beginning of Sudan’s civil war in April 2023, the RSF and its aligned militias have committed widespread atrocities, including war crimes, crimes against humanity, and genocide.

 

The following individuals have been added to OFAC’s SDN List:

• Adam, Elfateh Abdullah Idris of Sudan;
• Gutierrez Ochoa, Jose Luis of Mexico;
• Jimenez Tapia, Oscar Enrique of Mexico;
• Mohamed, Gedo Hamdan Ahmed of Sudan;
• Mohamed, Tijani Ibrahim Moussa of Sudan;
• Palacios Rodriguez, Jose Eduardo of Mexico;
• Rios Gonzalez, Jonathan Faustino of Mexico; and
• Rivera Miramontes, Carlos Humberto of Mexico.

 

The following entities have been added to OFAC’s SDN List:

 

• Administradora Y Comercializadora Del Mar, S.A. De C.V. of Mexico;
• Agencia De Servicios Turisticos Internacionales G8, S.A. De C.V. of Mexico;
• Asesoria Y Servicios Importadores, S.A. De C.V. of Mexico;
• Club Deportivo De Formacion Al Futbol Gmx, S.De R.L. De C.V. of Mexico;
• Colinas Proyectos Y Construcciones, S.A. De C.V. of Mexico;
• Constructora Palacios Pv, S.A. De C.V. of Mexico
• Corporativo Controlador Explora, S.A. De C.V. of Mexico
• Corporativo De Transferencias Internacionales De Bienes Raices, S.A. De C.V. of Mexico;
• Deep Blue Desarrollos, S. De R.L. De C.V. of Mexico;
• Deep Blue Servicios, S.A. De C.V. of Mexico;
• Estrategia PVR, S. De R.L. De C.V. of Mexico;
• High Land Park, S.A. De C.V. of Mexico;
• Hotel Management International, LLC of Mexico;
• Kovay Gardens (A.K.A. Vallarta Gardens) of Mexico;
• Ornitorrinco Inmobiliaria, S.A. De C.V. of Mexico;
• Punto 54, S.A. De C.V. of Mexico;
• Reef Administracion Avanzada, S. De R.L. De C.V. of Mexico;
• Solugas Soluciones En Gasolineras, S.A. De C.V. of Mexico; and
• VG Desarrollos De La Bahia, S.A. De C.V. of Mexico.

 

https://home.treasury.gov/news/press-releases/sb0399

 

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February 24, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Sergey Sergeyevich Zelenyuk (Mr. Zelenyuk) and his company, Matrix LLC (doing business as Operation Zero), as well as five associated individuals and entities, for their acquisition and distribution of cyber tools harmful to U.S. national security. Mr. Zelenyuk and Operation Zero trade in “exploits”—pieces of code or techniques that take advantage of vulnerabilities in a computer program to allow users to gain unauthorized access, steal information, or take control of an electronic device—and have offered rewards to anyone who will provide them with exploits for U.S.-built software.

 

The following individuals have been added to OFAC’s SDN List:

• Kucherov, Oleg Vyacheslavovich a national of Russia;
• Kucherov, Oleg Vyacheslavovich a national of Uzbekistan;
• Vasanovich, Marina Evgenyevna a national of Russia; and
• Zelenyuk, Sergey Sergeyevich a national of Russia.

 

The following entities have been added to OFAC’s SDN List

• Advance Security Solutions of Uzbekistan;
• Matrix LLC of Russia; and
• Special Technology Services LLC FZ of the U.A.E.

https://home.treasury.gov/news/press-releases/sb0404 and

https://www.state.gov/releases/office-of-the-spokesperson/2026/02/designation-of-russia-based-zero-day-exploits-broker-and-affiliates-for-theft-of-u-s-trade-secrets/

 

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February 25, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned over 30 individuals, entities, and vessels enabling illicit Iranian petroleum sales and Iran’s ballistic missile and advanced conventional weapons (ACW) production. Specifically, OFAC targeted additional vessels operating as part of Iran’s shadow fleet, which transport Iranian petroleum and petroleum products to foreign markets and serve as the regime’s primary source of revenue for financing domestic repression, terrorist proxies, and weapons programs.  OFAC also targeted multiple networks that enable Iran’s Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense and Armed Forces Logistics (MODAFL) to secure the precursor materials and sensitive machinery required to reconstitute ballistic missile and ACW production capacity, as well as proliferate unmanned aerial vehicles (UAVs) to third countries.

 

The following individuals have been added to OFAC’s SDN List:

 

• Abedini, Mohammad of Iran;
• Jafari, Mehrdad of Iran;
• Shariatzadeh, Ebrahim of Iran; and
• Zand, Mehdi of Iran.

 

The following entities have been added to OFAC’s SDN List:

• Adak Pargas Pars Trading Company of Iran;
• Altis Tekstil Makina Ticaret Limited Sirketi (a.k.a. Altis Textile Machinery Trading Company Limited) of Turkey;
• Arya Global Gida Sanayi Ve Ticaret Limited Sirketi of Turkey;
• Behengam Tadbir Qeshm Shipping And Maritime Services Company  (a.k.a. Behengam Tadbeer Qeshm Shipping Company) of Iran;
• Goldwave Maritime Services Inc. of the Marshall Islands;
• Ithaki Maritime And Trading S.A. of Panama;
• Kaito Navigation SA of Liberia;
• Mistral Fleet Co Ltd (a.k.a. Mistral Fleet Company Limited) of the British Virgin Islands;
• Mostafa Roknifard Prime Choice General Trading LLC (a.k.a. Mostafa Roknifard Perfumes And Cosmetics Trading LLC) of the U.A.E.;
• NYR Shipping CO. of the Marshall Islands;
• Ocean Kudos Shipping Company Limited of the Marshall Islands;
• Paros Maritime S.A. of Panama;
• Poros Maritime Ventures S.A. of Panama;
• Utus Gumrukleme Gida Tekstil Ithalat Ihracat Dis Ticaret Ve Sanayi Limited Sirketi of Turkey;
• Vast Marine Inc (a.k.a. Vast Marine Incorporated) of Liberia; and
• Wansa Gas Shipping Co. of the Marshall Islands.

 

The following vessels have been added to OFAC’s SDN List:

• Alaa (T8A5128) LPG Tanker Palau flag; Vessel Registration Identification IMO 9155341;
• Ateela 1 (EPCF9) Products Tanker Iran flag; Vessel Registration Identification IMO 9548990;
• Ateela 2 (EPCG2) Products Tanker Iran flag; Vessel Registration Identification IMO 9549009;
• Danuta I (T8A4990) LPG Tanker Palau flag; Vessel Registration Identification IMO 9193721;
• Felicita (D6A3040) Crude Oil Tanker Comoros flag; Vessel Registration Identification IMO 9167162;
• Gas Fate (3E6859) LPG Tanker Panama flag; Vessel Registration Identification IMO 9147394;
• Hoot (3FIQ9) LPG Tanker Panama flag; Vessel Registration Identification IMO 9267962;
• Luma (YJQY4) LPG Tanker Vanuatu flag; Vessel Registration Identification IMO 9034690;
• Niba (T8A4992) LPG Tanker Palau flag; Vessel Registration Identification IMO 9046784;
• North Star (8PPB) Crude Oil Tanker Barbados flag; Vessel Registration Identification IMO 9299563;
• Ocean Koi (8P2574) Crude Oil Tanker Barbados flag; Vessel Registration Identification IMO 9255933; and
• Remiz (3E8793) Crude Oil Tanker Panama flag; Vessel Registration Identification IMO 9223344.

 

https://home.treasury.gov/news/press-releases/sb0405 and https://ofac.treasury.gov/recent-actions/20260225

 

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February 25, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new, Venezuela-related Frequently Asked Question (FAQ 1238), pertaining to the resale of Venezuelan origin oil to Cuba.

 

Question 1238. Would OFAC approve the resale of Venezuelan origin oil to Cuba?

 

Answer: In accordance with the United States’ support and solidarity for the Cuban people, OFAC would implement a favorable licensing policy toward specific license applications seeking authorization for the resale of Venezuelan origin oil for use in Cuba. To qualify for this favorable licensing policy, the requested transactions would need to be consistent with the terms and conditions of Venezuela General License (GL) 46A, though applicants need not necessarily have an established U.S. entity and the limitations in GL 46A with respect to Cuba would not apply. This favorable licensing policy is directed towards transactions that support the Cuban people, including the Cuban private sector (e.g., exports for commercial and humanitarian use in Cuba). Consistent with applicable U.S. law and policy, transactions involving, or for the benefit, of any persons or entities associated with the Cuban military, intelligence services, or other government institutions, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 C.F.R. § 515.209, would not be covered by this favorable licensing policy.

As a reminder, the U.S. Department of Commerce primarily regulates the export or reexport of U.S.-origin oil to Cuba, as well as all other items subject to the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774). Treasury’s Cuban Assets Control Regulations generally authorize U.S. persons to engage in transactions ordinarily incident to the export of oil from the United States to Cuba, or the reexport of U.S.-origin oil from a third country to Cuba, where that export or reexport has been authorized by the Commerce Department. See 31 C.F.R. § 515.533(a). This authorization applies to transactions covered by applicable Commerce Department license exceptions, including License Exception Support for the Cuban People (SCP), 15 C.F.R. § 740.21, which authorizes exports and reexports of gas and other petroleum products to improve living conditions and support independent economic activity. In other words, U.S.-origin oil exports, as well as other gas and petroleum products covered by License Exception SCP, do not require separate OFAC authorizations. Exporters and reexporters are responsible for reviewing current Commerce Department guidance, https://www.bis.gov/media/documents/scp-gas-petroleum-faq.pdf, and ensuring that any transaction undertaken pursuant to License Exception SCP or any other license exception meet all applicable terms and conditions.

See FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.

 

https://ofac.treasury.gov/recent-actions/20260225_33

 

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February 26, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five Nicaraguan government officials who lead the principal financial, communications, and military agencies that enable Nicaragua’s Murillo-Ortega dictatorship to repress its people. The individuals sanctioned include the Director and Deputy Director of Nicaragua’s Financial Analysis Unit, the Minister of Labor, the Deputy Director General of the Nicaraguan Institute of Telecommunications and Postal Services, and the head of the Nicaraguan Army’s Directorate of Military Intelligence and Counterintelligence.

 

The following individuals have been added to OFAC’s SDN List:

• Flores Jimenez, Johana Vanessa of Nicaragua;
• Gutierrez Lopez, Leonel Jose of Nicaragua;
• Membreno Rivas, Denis, Managua of Nicaragua;
• Reyes Ochoa, Celia Margarita of Nicaragua; and
• SAENZ ULLOA, Aldo Martin of Nicaragua.

 

https://home.treasury.gov/news/press-releases/sb0409

 

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February 26, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 131C, “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.”

 

General License No. 131C Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities

All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the negotiation of and entry into contracts with Public Joint-Stock Company Oil Company Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “LIG Entities”) are authorized through 12:01 a.m. eastern daylight time, April 1, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control (“contingent contracts”).

 

All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG Entities are authorized through 12:01 a.m. eastern daylight time, April 1, 2026.

 

All blocked accounts of LIG Entities may be used, debited, or credited for the transactions authorized in this general license.

 

This general license does not authorize:

(1) The unblocking of any property blocked pursuant to any part of 31 CFR chapter V, except as authorized in paragraph (c);

(2) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, other than blocked persons described in paragraph (a) of this general license, unless separately authorized; or

(3) The transfer of funds to any person or account located in the Russian Federation.

 

Additionally, OFAC issued two amended, Russia-related Frequently Asked Questions (FAQs 1224 and 1225).

 

Question 1224: What negotiations does Russia-related General License 131C authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

Top of Form

Answer: On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131C, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131C expires on April 1, 2026.

 

GL 131C does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131C must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

 

As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

OFAC may revoke GL 131C at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

 

Question 1225: What activities do Russia-related General License 128B and General License 131C authorize related to Lukoil International GmbH (LIG)?

 

Answer: OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128B and GL 131C. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

• To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. This GL expires on April 29, 2026.
• To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B and 131C to extend the existing authorization until April 1, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

 

GL 128B and GL 131C expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131C. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128B and GL 131C authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

 

Both GL 128B and GL 131C also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

 

Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131C. Similarly, non-U.S. persons may rely upon GL 128B and GL 131C regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131C, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

 

https://ofac.treasury.gov/recent-actions/20260226

https://ofac.treasury.gov/faqs/1224

https://ofac.treasury.gov/faqs/1225