This newsletter is a listing of the latest changes in export control regulations through March 31, 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
White House Unveils Cyber Strategy for America
March 6, 2026: The White House released “Cyber Strategy for America,” outlining the Administration’s priorities for ensuring that America remains unrivaled in cyberspace. It calls for unprecedented coordination across government and the private sector to invest in the best technologies and continue world-class innovation, and to make the most of America’s cyber capabilities for both offensive and defensive missions.
This strategy communicates the Administration’s cyber vision and approach to the American people, to Congress, to our partners in industry and allies across the globe—and also to adversaries. It explains the Administration’s priorities, summarized in six policy pillars, which will guide action and resourcing through the follow-on policy vehicles.
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Combating Cybercrime, Fraud, And Predatory Schemes Against American Citizens
March 6, 2026: 91 Fed. Reg. 12051: The President issued EO 14390 Combating Cybercrime, Fraud, And Predatory Schemes Against American Citizens, in which the policy of the U.S. is to protect Americans from, and harden our financial and digital systems against, these threats. The United States shall counter attacks on Americans with a commensurate response that includes law enforcement, diplomacy, and potential offensive actions. It is further the policy of the United States to provide support to victims of these crimes, expand public alerts, and prioritize protection for those most at risk to end the exploitation and victimization of Americans.
The EO directed the Secretary of State, the Secretary of the Treasury, the Secretary of War, the Attorney General, and the Secretary of Homeland Security, in consultation with the Office of the National Cyber Director, and in coordination with the Assistant to the President and Homeland Security Advisor (APHSA) to:
- Review the relevant operational, technical, diplomatic, and regulatory frameworks in place to determine how each can be improved to best combat Transnational Crime Organizations (TCOs) engaged in cyber-enabled crime and similar predatory schemes against Americans;
- Submit to the President, through the APHSA, an action plan that identifies the TCOs responsible for scam centers and cybercrime and proposes solutions to prevent, disrupt, investigate, and dismantle these TCOs;
- Submit a recommendation to the President, through the APHSA, regarding the establishment of a Victims Restoration Program designed to provide, to the greatest extent authorized by law and in consideration of the Department of Justice’s goal of serving all victims of crime, restoration or remission to victims of cyber-enabled fraud schemes from funds clawed back, forfeited, or seized from the TCOs that perpetrate such schemes; and
- Engage with foreign governments to demand enforcement actions against TCOs operating within their borders and greater cooperation with United States law enforcement.
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Adjusting Certain Delegations Under The Defense Production Act
March 13, 2026: 91 Fed. Reg. 14391: The President issued EO 14391 amending EO 13603 dated March 16, 2012(National Defense Resources Preparedness). Executive Order 13603 delegates certain authorities of the President under the Defense Production Act (50 U.S.C. 4501 et seq.), to specified executive department and agency (agency) heads. This order also clarifies section 2(a) of Executive Order 14156 of January 20, 2025 (Declaring a National Energy Emergency).
EO 14391 amended Section 203 of Executive Order 13603 by striking the phrase “Secretary of Commerce” and inserting, in lieu thereof, “Secretary of Commerce and the Secretary of Energy, each of whom may exercise such delegated authority independently of the other”.
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Fact Sheet: The President Strengthens U.S.-Japan Alliance for the Benefit of All Americans – The White House
March 19, 2026: The Administration released a fact sheet announcing new initiatives to strengthen the U.S.-Japan Alliance, enhance economic security, and bolster deterrence to advance a free and open Indo-Pacific.
Of note, the United States welcomed Japan’s commitment to rapidly strengthen its own defense capabilities, increase its defense budget, and continue partnering with U.S. forces in Japan and the region.
- The United States and Japan affirmed their commitment to deploying advanced capabilities in Japan to enable a strong denial defense posture. This year, the two sides will maintain close coordination, building on the successful 2025 deployment of the U.S. Typhon missile system to mainland Japan.
- Following the bilateral feasibility study for AIM-120 Advanced Medium-Range Air-to-Air Missile (AMRAAM) co-production, the two countries will scope Japan’s future role in increased AMRAAM production capacity.
- In support of missile defense cooperation, the two sides will rapidly increase by fourfold the production of Standard Missile 3 Block IIA missiles in Japan.
- The United States welcomed Japan’s commitment to develop a secure and sovereign cloud platform for government data to enhance bilateral information sharing, planning, and coordination.
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Department of State
Defense Trade Advisory Group; Notice of Membership
March 19, 2026: The U.S. Department of State’s Bureau of Political-Military Affairs (the Bureau) is accepting membership applications for the Defense Trade Advisory Group (DTAG). The Bureau is interested in applications from subject matter experts, including from the United States defense industry, relevant trade and labor associations, and academic and foundation personnel.
DTAG members’ responsibilities include:
- Making recommendations in accordance with the DTAG Charter and the FACA.
- Making policy and technical recommendations within the scope of the U.S. export controls as set forth in the AECA, the ITAR, and appropriate directives.
Please note that DTAG members may not be reimbursed for travel, per diem, and other expenses incurred in connection with their duties as DTAG members.
How to apply: Applications in response to this notice must contain the following information: (1) Name of applicant; (2) affirmation of U.S. citizenship; (3) organizational affiliation and title, as appropriate; (4) mailing address; (5) work telephone number; (6) email address; (7) resume; and (8) summary of qualifications for DTAG membership.
This information may be provided via two methods:
- Emailed to the following address: DTAG@State.Gov. In the subject field, please write, “ DTAG Membership Application. ”
- Send hardcopy to the following address: Paula Harrison, PM/DDTC, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political-Military Affairs, U.S. Department of State, Washington, DC 20522-0112. If sent via regular mail, we recommend you call Ms. Harrison (202-663-3310) to confirm she has received your package.
All applications must be postmarked no later than 15 days after the publication date of this notice.
Fiscal Year 2025 U.S. Arms Transfers and Defense Trade
March 16, 2026: The U.S. Department of State released the Fiscal Year 2025 U.S. Arms Transfers and Defense Trade
Total Sales:
In FY 2025 the number for total sales, both government to government Foreign Military Sales, and exports licensed via Direct Commercial Sales was $331.18 billion. This represents a 3.92 percent increase over the FY 2024 figure of $318.70 billion.
Foreign Military Sales:
In FY 2025 the total value of transferred defense articles and services and security cooperation activities conducted under the Foreign Military Sales system was $104.38 billion. This represents an 11.47 percent decrease, down from $117.85 billion in FY 2024. In FY 2025, the Department of State oversaw 16,098 FMS cases with an open case value of over $934 billion.
Direct Commercial Sales:
The total authorized value for privately contracted Direct Commercial Sales (DCS) authorizations for FY 2025 was $226.8 billion, which includes the value of hardware, services, and technical data authorized for exports, temporary imports, reexports, retransfers, and brokering. This represents a 12.9 percent increase, up from $200.8 billion in FY 2024.
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Directorate of Defense Trade Controls (DDTC)
Registration Application Enhancement Release
March 26, 2026: DDTC announced that beginning March 27, 2026, email notifications will be sent the day after a registration expires to the Senior Officer, Points of Contact, and Corporate Administrators associated with the registration. This notification is intended to provide timely prompt action for renewal, minimize the duration of any registration lapses, avoid lapse-related fees, and help organizations maintain ITAR compliance.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_homepage
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DDTC Name And Address Changes Posted To Website
March 1 through March 31, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Curtiss-Wright foreign subsidiary Ultra Nuclear Limited changed its name to Curtiss-Wright Wimborne Limited due to corporate restructuring.
- Mitsubishi Space Software Co., Ltd. changed its name to Mitsubishi Electric Software Corporation due to corporate restructuring.
- Muirhead Avionics UK changed its address from 3 The Square, Heathrow, UB2 5NH, South, United Kingdom to Muirhead Avionics UK, Quadrant House, 50 Heron Drive, Langley, Berkshire, SL3 8XP, United Kingdom.
- Neotek changed its name to RTsys Monitoring Solutions due to corporate rebranding.
- Schleifring North America, LLC’s subsidiary Electro-Miniatures Corp. changed its address from 68 W. Commercial Ave., Moonachie, NJ 07074 to 80 Hancock Street, Lodi, NJ 07644.
- TUSAS Motor Sanayii A.S. changed its address from Muttalip Mevkii Mrk Pk 610, Eskisehir 26003, Turkey to Esentepe Mahallesi Cevre Yolu Bulvari, No:356, Tepebasi, Eskisehir 26210, Turkey.
- GE Aviation Systems Australia Pty Ltd changed its address from 34 Boronia Road, Brisbane Airport 4008, Australia to 34 Boronia Road, Brisbane Airport, Brisbane 4008, Queensland, Australia.
- DSV Air & Sea, Inc. Entities Names and Locations due to corporate restructuring
- From: Avenida Presidente Riesco nùmero 5335 Oficinas 504 y 505, L 7561127 Santiago Chile
To: DSV Air & Sea S.A. Avenida Andres Bello 2687 Office 801 Building Del Pacifico, Las Condes, Santiago, Chile 755066 Santiago Chile
- From: Schenker d.o.o. Ulica Franje Lucica 32 10090 Zagreb Croatia
To: DSV Hrvatska d.o.o. Zelena aleja 55 10410 Velika Gorica Croatia; and
DSV Road Croatia d.o.o. Ulica Franje Lucica 32 10090 Zagreb Croatia
- From: AS Schenker Pärnu mnt 535 31136 Chihuahua 76404 Sakuv
To: DSV Air & Sea AS Pärnu mnt. 535 76401 Saku Vald Estonia; and
DSV Road AS Pärnu mnt 535 76404 Saku vald, Estonia Estonia
- From: Schenker A.E. Thesi Gropa Kyrillos 19300 Asproryrgos Greece
To: DSV Air & Sea Single Member S.A. 100 Alimou Ave. 164 52 Argyroupolis (Athens) Greece;
DSV Road Single Member S.A. 100, Alimou AV 164 52 Argyroupolis Athens Greece; and DSV Road Greece Thesi Gropa Kyrillosv 19300 Asproeyrgos Greece
- From: SIA Schenker Katlakalna iela 11c 1073 Riga Latvia
To: SIA DSV Latvia Krustpils street 31 1073 Riga Latvia
- From: Schenker Philippines Inc KM. 19, WSR, Sabrina Compound, Brgy. Marcelo Green Village 1700 Paranaque City Philippines
- To: DSV Air & Sea Inc. 6th Flr. West Tower 8912 Asean Avenue Bldg. Cor. N. Abueva 1700 Paranaque City Philippines;
DSV Contract Logistics, Inc. KM19 Sabrina Compound West Service Road Marcelo Green Village 1700 Paranaque City Philippines;
DSV Global Solutions Inc People’s Technology Complex, SEZ, Brgy Maduya, Carmona 4116 Cavite Philippines;
DSV Ecozone Logistics, Inc., Standard Factory Building 3, Laguna Technopark Brgy. Mamplasan 4024 Biñan Laguna Philippines; and
DSV Road KM19 West Service Rd., Sabrina Compound Marcelo Green 1700 Paranaque City Philippines
- From: Schenker Logistics AB Hangarvägen 1 438 70 Landvetter Sweden;
Schenker AB Österleden 201 261 51 Landskrona Sweden; and
Schenker Logistics AB Hangarvägen 1 438 70 Landvetter Sweden
To: DSV Air & Sea AB Österleden 201 261 51 Landskrona Sweden;
DSV Road AB Moelndalsvaegen 83 41285 Gothenburg Sweden; and
DSV Contract Logistics AB Österleden 201 261 51 Landskrona Sweden
- From: Schenker Schweiz AG Rautistr. 77 8048 Zuerich Switzerland
To: DSV Air & Sea AG St. Jakobs-Strasse 220 4052 Basel Switzerland; and
DSV Logistics S.A. Via Passeggiata 24 6828 Balerna, Switerland
- From: Schenker Saudi Arabia LLC Riyadh Avenue Mall, Avenue 2, 3rd Floor Hai Ul Murabba Riyad 51615 Riyadh Saudi Arabia
To: DSV Air and Sea for Logistics Services Company Blue Tower – 5th Floor (B-Wing), King Faisal Road – 13th street, P.O. Box 1499 31952 Al-Khobar Saudi Arabia; and
DSV Contract Logistics for Logistics Services Company Sinaeyat Slay – Istanbul Street 11464 Riyadh Saudi Arabia
- From: UAB “Schenker” Savanoriu ave. 5 03116 Vilnius Lithuania
To: DSV Lithuania UAB Stasylu 21 02244 Vilnius Lithuania
- From: Schenker (NZ) Limited 50 Richard Pearse Drive, Airport Oaks 2022 Auckland New Zealand
To: DSV Air & Sea Limited 19 Landing Drive, Auckland International Airport 2022 Auckland New Zealand - From: Schenker Logistics – L.L.C – S.P.C Hamdan bin Mohammed Street Abu Dhabi United Arab Emirates
To: DSV Contract Logistics PJSC PO Box 93971, Street No. 10, Sector M19, Mussafah Abu Dhabi United Arab Emirates
- From: Schenker of Canada Ltd. L4V 1W5 Mississauga, Ontario 5935 Airport Road, 10th floor Canada
To: DSV Air & Sea Inc. 2200 Yokon Court Ontario L9E 1N5 Milton Canada;
DSV Road Inc 2200 Yokon Court Ontario L9E 1N5 Milton Canada; and
DSV Contract Logistics Inc. 2200 Yokon Court Ontario L9E 1N5 Milton Canada
- From: Schenker France SAS Z.I. Nord 85600 Montaigu France
To: DSV Air & Sea SAS 9-23 Chemin des Petits Marais 92230 Gennevilliers France;
DSV Road SAS 19-23 Chemin des Petits Marais 92230 Gennevilliers Cedex France; and
DSV Contract Logistics SAS 33, Rue de Reckem 59960 Neuville en Ferrain France
- From: Schenker Vietnam Co. Ltd 14th Floors-Tower A, 285 Cach Mang Thang 8 Hoa Hung Ward Ho Chi Minh City Viet Nam
To: DSV Air & Sea Company Limited 3B FLOOR REPUBLIC PLAZA BUILDING, 18E CONG HOA ST., WARD 4, TAN BINH DISTRICT Ho Chi Minh City Vietnam
- From: Schenker Italiana S.p.A. (à DSV Road Spa) Via Fratelli Bandiera 29 20068 Peschiera Borromeo (MI) Italy
To: DSV SpA (à DSV Air&Sea Spa) Via Dante Alighieri 134 20096 Pioltello Italy; and
DSV Solutions S.R.L (à DSV Contract Logistics Srl.) Via Dante Alighieri 134, Frazione Limito 20096 Pioltello Italy
- Luerssen Australia Pty Ltd changed its ownership and name as follows:
- Previous Owner Name and Address:
NVL B.V. Co. ZKG Zum Alten Speicher 11 28759 Bremen, Germany
New Owner Name and Address:
Civmec Limited (CVL) 16 Nautical Drive, Henderson, WA 6166 Australia
- Entity Named on Existing Agreement:
Luerssen Australia Pty Ltd. (Luerssen) 16 Nautical Drive, Henderson, WA 6166 Australia
New Entity:
Civmec Defence Industries (CDI) 16 Nautical Drive, Henderson, WA 6166 Australia
- L3Harris Interstate Electronics Corporation changed its address from 602 E. Vermont Avenue, Anaheim, California 92805 to 22745 Savi Ranch Parkway, Yorba Linda, California 92887
- General Electric International Inc. changed its name to Arcam AB due to corporate restructuring.
- LIG Nex1, Ltd. changed its name to LIG Defense & Aerospace Co., Ltd. due to corporate rebranding.
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DDTC Frequently Asked Questions (FAQs)
Q: How can a user become a Corporate Administrator (CA) in DECCS?
A: (Updated 3/2/2026) A user can become a Corporate Administrator (CA) in DECCS through the following methods:
- Designation by an Existing CA
An existing Corporate Administrator can designate any user as a CA via the DECCS User Management (UM) application.
- Senior Officer (SO) Request
If you are a Senior Officer, you can use last year’s signed registration notification letter from DDTC in place of a CA Request letter, provided the letter includes:
- Company name
- Registration code
- Your name as the Senior Officer
- Submission of a CA Request Letter
Send a CA Request letter on company letterhead in PDF format with the following details:
- Date
- Company name and mailing address
- DDTC registration code
- Brief description of the request (e.g., Request for John Smith to be designated as a CA)
- Title and contact information of the requested CA (name, phone number, and email used for DECCS enrollment)
- Senior Officer (SO)/Empowered Official (EO) signature (handwritten or cryptographic-based; font-based signatures are not allowed) in addition to their title and contact information.
Important Notes
- Ensure your company has no new registrations in progress before submitting the CA Request letter. Any renewal registration will fail if new registrations are active.
- It is recommended to have multiple Corporate Administrators to avoid disruptions due to absences or departures.
Submission Methods
Send the CA Request letter to DDTC Help Desk using one of the following methods:
- Update an Existing Support Case: Log into DECCS, go to My Support Cases, click Needs Attention, locate the case, and upload the CA Request letter.
- Create a New Support Case: Log into DECCS, go to My Support Cases, and click Create a New Support Case. Refer to How do I submit a Support Case request?
Processing Time
Once the request is received, allow 1–2 business days for completion.
Q: How do I add a new Corporate Administrator (CA) in DECCS?
A: To add a new Corporate Administrator (CA), you must already be a CA yourself. Follow these steps to designate another user as a CA:
- Log in to DECCS and click the Applications menu in the top navigation bar.
- Select the User Management option.
- In the Company Users section, find the user you want to make a CA.
- Check the CA checkbox next to the user’s email address.
- Once the change is applied, a green banner will appear at the top of the screen with the message: “User Updated Successfully.”
The user will now have Corporate Administrator privileges and can manage user accounts and access within your organization.
Q: How do I switch my DECCS profile to a new email address?
A: To switch your DECCS profile to a new email address, you’ll need to create a new DECCS account using your new email and have your Corporate Administrator (CA) connect it to your company’s profile.
You may need to do this if you’ve changed companies, updated your organization’s email domain, or no longer have access to your old email account.
Steps:
- Create your new DECCS account – Go to https://deccs.pmddtc.state.gov/deccs and click Enroll.
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- Register using your new email address and complete the Okta verification process.
- Request company access- If you’re a Corporate Administrator (CA), log into DECCS with your old account and invite your new email under Applications → User Management → Add User.
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- If you’re not a CA, ask your CA to send this invitation.
- Accept the invitation – Log into DECCS with your new account and accept the company invitation under User Management.
- Update roles and permissions (CA required) – Your CA must assign your Registration and Licensing roles to the new account and mark it as a Corporate Administrator, if applicable.
- Remove your old account – Once the new account is active, your CA should remove your old email from the company user list.
- Clean up – Delete the old account from your Okta Verify app.
- Submit a Support Case (from your old account email) requesting deactivation of the old DECCS account. Include the old email address in your message.
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REMINDER: It’s Time For Annual Sales Report Filings To Be Made With DDTC For Manufacturing License Agreements And Warehousing Distribution Agreements For Sales And Transfers That Occurred In 2025
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
Israel
Sweden
United Arab Emirates
Jordan
Kuwait
United Kingdom
Republic of Korea
Japan
Belgium
https://www.state.gov/israel-munitions-and-munitions-support/
https://www.state.gov/united-arab-emirates-advanced-medium-range-air-to-air-missiles-amraams/
https://www.state.gov/government-of-jordan-aircraft-repair-return-and-spares/
https://www.state.gov/japan-hyper-velocity-gliding-projectile-hvgp-program-support/
https://www.state.gov/belgium-communications-equipment/
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Department of Commerce – Bureau of Industry and Security (BIS)
Exports of U.S.-Origin Gas and Petroleum Products to Cuba
March 4, 2026: BIS updated its guidance regarding the availability of License Exception 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. Certain transactions that meet SCP terms may be authorized without a license, and applications that otherwise qualify will be returned without action with instruction to use the exception. Exporters are responsible for ensuring that all SCP conditions are met and should carefully review § 740.21 before proceeding.
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Suspension Related to Cuban-Owned Banks
March 4, 2026: BIS suspended the availability of License Exception Support for the Cuban People (SCP) under § 740.21(b)(1) for any export, reexport, or transfer involving the deposit of foreign funds into a Cuban‑owned bank. BIS determined that such transactions present an unacceptable risk of primarily benefiting the Cuban government and its military or intelligence services. This suspension does not apply to transactions that avoid Cuban banks, such as those routed through third‑country financial institutions, nor to shipments already en route by March 4, 2026, if completed by April 3, 2026. Exporters remain responsible for ensuring full compliance with § 740.21 and all SCP conditions before proceeding.
BIS updated its Cuba Export Controls Country Guidance by adding Suspension Related to Cuban-Owned Banks.
BIS determination to suspend the availability of License Exception SCP under § 740.21(b)(1) for any export, reexport, or transfer (in-country) involving a Cuban owned bank
- There are longstanding and documented issues of diversion and fees associated with Cuban banks. The Cuban banks form the basis of the regime’s financial infrastructure, and many are designated on the Cuba Restricted List due to being under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel. It is well established that it is not the policy of the United States to permit transactions that significantly benefit the Cuban government or its designated military institutions.
- Accordingly, transactions involving the deposit of foreign funds into Cuban government banks, including those on the Cuba Restricted List or associated with the military and intelligence services, may serve to primarily generate revenue for or contribute to the operation of the Cuban state.
- Taking these considerations above into account and the need to protect U.S. national security and foreign policy interests, BIS has determined that there is an unacceptable risk that transactions involving Cuban banks may primarily benefit the Cuban government, contrary to the purpose of License Exception SCP of supporting independent economic activity in Cuba.
- Pursuant to § 740.2(b) of the EAR, which specifies that “all License Exceptions are subject to revision, suspension, or revocation, in whole or in part, without notice to protect U.S. national security or foreign policy interests,” BIS is informing all exporters, reexporters, and transferors that License Exception Support for the Cuban People (SCP), § 740.21(b)(1), is suspended as of March 4, 2026, for any export, reexport, or transfer (in-country) involving the deposit of foreign funds into a Cuban owned bank.
- This BIS suspension does not apply to exports, reexports, or transfers (in-country) that do not involve Cuban banks, e.g., involving third country banks or other financial payment systems that do not involve the deposit of foreign funds into Cuban banks. This BIS suspension also does not apply to any export or reexport that was en route aboard a carrier to a port of export or reexport on March 4, 2026, pursuant to actual orders for export or reexport to Cuba, provided that the export or reexport is completed no later than April 3, 2026.
Updated Guidance Regarding Available EAR License Exceptions for Exports of Gas and Petroleum Products to Cuban Private Sector Entities and Activities
- The Bureau of Industry and Security (BIS) has been receiving questions from potential exporters on the EAR requirements and potential EAR authorizations that may be available to authorize exports of gas and petroleum products and reexports of U.S.-origin gas and petroleum products for private sector use, including for addressing humanitarian needs in Cuba.
- In general, a license is required to export and reexport gas and other petroleum products that are subject to the EAR to Cuba pursuant to § 746.2(a). However, as with any export or reexport that is subject to a license requirement, the exporter or reexporter should first evaluate whether a license exception is available to authorize the export or reexport.
- In particular, exporters and reexporters of gas and petroleum products subject to the EAR to the Cuban private sector should review the general restrictions under § 740.2 and § 740.21. As explained below, gas and other petroleum products exported and reexported to Cuban private sector entities or individuals for personal use (or their fa may be authorized under License Exception SCP.
- Exporters and reexporters are advised that if a license application is submitted to BIS that otherwise meets the terms and conditions of License Exception SCP, those applications will be returned without action (RWA’d) by BIS with a direction to the applicant to export or reexport the items pursuant to License Exception SCP.
- BIS provides the following FAQ to further assist public understanding:
Q.1: Would License Exception Support for the Cuban People (SCP) (§ 740.21 of the EAR) allow an exporter or reexporter to export or reexport gas and other petroleum products to Cuban private sector entities for private sector use, or directly to individual Cubans for their personal or family use?
A.1: Yes, provided that all the applicable terms and conditions of License Exception SCP are met. Specifically, there are two authorizing paragraphs under License Exception SCP under paragraph (b) (Improving living conditions and supporting independent economic activity), which may be available to authorize these types of exports and reexports of gas and other petroleum products to Cuba. License Exception SCP provides a general authorization for exports under certain applicable conditions, as explained below, and does not contain any specific limitations on applicability based on quantity or value of the items, or exporter or reexporter.
- 740.21(b)(1). Exports to private sector for private sector use. If the gas and other petroleum products are being exported (or reexported) for use by the Cuban private sector for private sector use, then paragraph (b)(1) of License Exception SCP, which authorizes items for use by the Cuban private sector for private sector economic activities, may be available to authorize these types of exports and reexports. To qualify, exports must be both (1) for use by the Cuban private sector, and (2) for private sector economic activities, including those addressing humanitarian needs in Cuba. Per § 740.21(b)(1)(i) and (ii), License Exception SCP does not apply to any transactions, whether to Cuban private sector entities or otherwise, which primarily generate revenue for the state; or contribute to the operation of the state, including through the construction or renovation of state-owned buildings.
- 740.21(b)(2). Exports sold directly to individuals in Cuba for their personal use.
If the gas and other petroleum products are sold directly to individuals in Cuba for their personal use, then paragraph (b)(2) of SCP, which authorizes items sold directly to individuals in Cuba for their personal use (or their immediate family’s personal use), may be available to authorize exports and reexports of such products.
Paragraph (b)(2) does not require the products to be exported or reexported directly to the individuals; however, the products must ultimately be destined for these eligible end users (and/or their families) for their personal use.
This authorization applies only if the gas or other petroleum products are sold directly to individual Cubans for their personal use or the use of their immediate family. It does not apply if any of the products are sold or transferred to proscribed persons or entities in Cuba, including employees of the Ministry of Defense or Ministry of the Interior, senior officials of certain Cuban government organizations, labor unions, and other Cuban government affiliated organizations, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 CFR 515.209.
Note: Exporters and reexporters are responsible for ensuring that all of the applicable terms and conditions of License Exception SCP are met. Please review EAR § 740.21 — License Exception Support for Cuban People (SCP) — carefully to ensure that your transaction meets all the criteria for use of the license exception. Exporters who are unable to determine if they can satisfy all terms and conditions of License Exception SCP should submit an application for an individual validated license.
https://www.bis.gov/media/documents/030426-scp-gas-petroleum-bank-faq.pdf
https://www.bis.gov/licensing/country-guidance/cuba-export-controls
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Department of Commerce – International Trade Administration
Department of Commerce Announces New American AI Exports Program Phase
March 16, 2026: The U.S. Department of Commerce announced further implementation of the American AI Exports Program with a Call for Proposals from U.S. industry-led consortia to export full-stack AI technology packages. Under President Donald J. Trump’s AI Action Plan and export directives, the Department of Commerce is implementing a full-stack AI export package promotion program to advance America’s AI leadership globally.
Beginning April 1, 2026, and for 90 days, industry-led consortia may submit proposals for full-stack AI export packages, including AI optimized computer hardware, data center storage, models, cybersecurity measures, and applications for various sectors.
The call for proposals includes two types of industry-led consortia: pre-set consortium and on-demand consortium. Pre-set consortia demonstrate capability across all layers of the AI technology stack and maintain global offerings ready for deployment on an ongoing basis. These will become the U.S. Government’s offerings to allies and partners around the world. On-demand consortia are formed by industry in response to a specific opportunity identified by the Program and need only cover the stack layers required for the specific deal. These on-demand consortia are formed as “custom-made” options for specific opportunities.
Both pre-set and on-demand consortia are designated through a single selection process: the Secretary of Commerce, in consultation with the Secretary of State, the Secretary of War, the Secretary of Energy, and the Director of the Office of Science and Technology Policy, selects proposals for inclusion in the Program. Once approved, full-stack AI technology can be available to trusted foreign buyers of U.S. technology.
Under the Program, approved consortia may also receive support from across the U.S. Government, including priority for export control license reviews, prioritized access to U.S federal credit programs, government-to-government engagement via direct advocacy, and dedicated interagency coordination.
Full program information and proposal processes will be published in a forthcoming Federal Register notice.
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Federal Communications Commission
On March 23, 2026, the Federal Communications Commission updated its Covered List to include all consumer-grade routers produced in foreign countries. Routers are the boxes in every home that connect computers, phones, and smart devices to the internet. This followed a determination by a White House-convened Executive Branch interagency body with appropriate national security expertise that such routers “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.
See our articles on this topic on FD Associates’ LinkedIn page.
https://docs.fcc.gov/public/attachments/DOC-420034A1.pdf
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 25, 2026: Gerald Eddie Brown, Jr., 65, a former U.S. Air Force officer and pilot, was arrested in Jeffersonville, Indiana, and charged by criminal complaint for providing, and conspiring to provide, unauthorized defense services to Chinese military pilots in violation of the Arms Export Control Act.
Since August 2023, Brown willfully conspired with foreign nationals to provide combat aircraft training to pilots in the Chinese Air Force, known as the People’s Liberation Army Air Force (PLAAF). This training was a defense service under the International Traffic in Arms Regulations (ITAR) and Brown lacked the required license from the State Department’s Directorate of Defense Trade Controls to provide that training to foreign persons or foreign military units.
Brown served for more than 24 years in the U.S. Air Force and retired in 1996 with the rank of Major. During his military career, Brown commanded sensitive units with responsibility for nuclear weapons delivery systems, led combat missions, and served as a fighter pilot instructor and simulator instructor on a variety of fighter and attack aircraft, including the F-4 “Phantom II,” F-15 “Eagle,” F-16 “Fighting Falcon,” and the A-10 “Thunderbolt II” (Warthog). Brown then served as a commercial cargo pilot and, most recently, as a contract simulator instructor for two different U.S. defense contractors training U.S. military pilots on flying the A-10 and the F-35 Lightning II Joint Strike Fighter.
In August 2023, Brown began arranging 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 pleaded 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 to steal sensitive military and export-controlled data for the PRC. Su Bin was sentenced to nearly four years in prison. Su Bin and his company PRC Lode Technology Company also were 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 the resumé he prepared for his application, Brown wrote his “objective” as “Instructor Fighter Pilot.” A co-conspirator told Brown that he hoped Brown would be assigned to “my base, but otherwise you’ll go where is the local equivalent as the [U.S. Air Force] Weapon School.” Later, Brown stated to a co-conspirator that, upon his arrival in China, “Now…. I have the chance to fly and instruct fighter pilots again!”
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March 17, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that TradeStation Securities, Inc. (“TradeStation”) has agreed to pay $1,110,661 to settle its potential civil liability for 481 apparent violations of OFAC sanctions programs arising from TradeStation’s provision of brokerage and investment services to persons in Iran, Syria, and Crimea, between June 2021 and June 2022. The settlement amount reflects OFAC’s determination that TradeStation’s conduct was non-egregious and was voluntarily self-disclosed.
TradeStation implemented compliance systems to comply with U.S. sanctions. The compliance systems included:
- Background checks of prospective customers that include screening against OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) and rescreenings of its existing customers against the SDN List on a daily basis. Each customer’s primary residence is screened to ensure they do not reside in a sanctioned jurisdiction.
- IP Geo-blocking technology to verify the location of its users while they utilized TradeStation’s web-based and mobile platforms to prevent access to TradeStation’s platforms from sanctioned jurisdictions. A key element of this system was a firewall designed to deny users with IP addresses associated with sanctioned jurisdictions from accessing TradeStation’s systems (the “first-tier geo-blocking”). TradeStation ran a separate third-party IP address verification tool that acted as a second layer of defense by authenticating a user’s IP address upon login to TradeStation’s web-based and mobile platforms and denied access based on location (the “second-tier geo-blocking”).
- Subscription to a third-party service that alerted TradeStation’s sanctions compliance personnel to access attempts that had been prevented by the geo-blocking controls. These notifications, which were delivered daily, documented efforts by TradeStation clients to access its platforms in jurisdictions subject to OFAC sanctions and other certain jurisdictions.
The violations are the result of:
- Failures In Tradestation’s IP Geo-Blocking Measures
- TradeStation designed and implemented proprietary software to improve the functionality and the overall user experience of TradeStation’s mobile platform. This new software, however, inadvertently rendered TradeStation’s second-tier geo-blocking ineffective for users of its mobile platform. Instead of identifying and screening the user’s IP address at the time of an attempted login to prevent users from sanctioned jurisdictions from trading, the second-tier geo-blocking protocol detected the IP address of the U.S.-located server from which TradeStation’s new mobile platform software ran. This prevented the second-tier geo-blocking controls from functioning as designed, rendering them incapable of identifying users in Iran, Syria, and Crimea.
- Additionally, one of TradeStation’s employees inadvertently failed to reenable the first-tier geo-blocking control after disabling it to install a software update from TradeStation’s cloud services provider. This left TradeStation’s first-tier geo-blocking controls effectively disabled, and they remained so for nearly 12 months. During this period, TradeStation was not restricting access to its mobile platform by users with IP addresses associated with sanctioned jurisdictions (although sanctioned users attempting to access the web-based platform would have been blocked by the second-tier geo-blocking controls). Consequently, users located in Iran, Syria, and Crimea were able to access TradeStation’s mobile platform and execute 481 trades during this time
- Failures To Test Or Validate Sanction Compliance Systems
- TradeStation developed an automated testing tool for its on-premises servers that would simulate access attempts by users with IP addresses associated with sanctioned jurisdictions. However, TradeStation later discovered that its third-party internet service and cloud providers were blocking these test access attempts before they could reach TradeStation’s systems. TradeStation discontinued the use of this tool without replacing it, and, as a result, TradeStation had no effective testing mechanism—neither related to its on-premises servers nor its mobile platform—in place to ensure that its IP geo-blocking controls were functioning as intended at the time the 481 apparent violations occurred.
- TradeStation maintained a third-party service that alerted sanctions compliance personnel of access attempts from sanctioned jurisdictions. On September 21, 2021, a TradeStation-affiliated employee received an email from the third-party provider of its daily notifications that TradeStation’s subscription would be expiring. This employee failed to renew the subscription and did not notify others in TradeStation’s sanctions compliance department about the expiration of the daily notifications. For a period of over eight months, TradeStation’s sanctions compliance personnel failed to address the absence of its once-daily OFAC alerts and did not consider or act on what the lack of notifications might have signaled about TradeStation’s sanctions compliance program.
Key Take Aways:
OFAC made the point to highlight:
- The importance of regular testing and auditing to ensure sanction compliance controls are effectively mitigating risk and preventing violations. The most well-designed sanctions compliance program can be rendered wholly ineffectual by human and technical errors. Comprehensive, independent, and objective testing and auditing can help catch problems early and provide opportunities for remediation, thereby limiting risk of violating sanctions.
- Regular testing and auditing also provide opportunities for evaluating sources of sanctions risk and ensuring that appropriate controls are in place to address them. Controls should be well designed to address particular sanctions risks, including those presented by particular technology offerings. These controls may include appropriately calibrated screening protocols, geo-blocking controls, and Virtual Private Network detection software. They may also include controls to validate proper system operation and execution following any outage, including due to planned maintenance or upgrade.
- Companies should not treat testing and auditing as box-checking exercise. Sanctions risks are dynamic and may fluctuate as prohibitions change or as businesses evolve. While technological solutions are often a critical part of an effective sanctions compliance program, firms should ensure they are not overly relying on a patchwork of software or taking a “set it and forget it” approach to compliance.
https://ofac.treasury.gov/recent-actions/20260317
https://ofac.treasury.gov/media/935351/download?inline
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March 19, 2026: The Department of Justice charged Yih-Shyan “Wally” Liaw, Ruei-Tsang “Steven” Chang, and Ting-Wei “Willy” Sun, for allegedly conspiring to divert high-performance computer servers assembled in the United States and integrating sophisticated U.S. artificial intelligence technology manufactured by Nvidia Corporation to China, in violation of U.S. export controls laws. Liaw, a U.S. citizen, and Sun, a citizen of Taiwan, were arrested and will be presented in the Northern District of California. Chang, a citizen of Taiwan, remains a fugitive.
Liaw is a co-founder, board member, and Senior Vice President of Business Development of Super Micro Computer, a publicly traded U.S.-based manufacturer that designs and builds high-performance computer servers for artificial intelligence and cloud computing applications, including servers that integrate Nvidia artificial intelligence graphics processing units (GPUs). Chang is a general manager in the U.S. Manufacturer’s Taiwan office. Sun is a third-party broker and “fixer” who has worked with Liaw, Chang, and others to divert U.S.-export controlled technology to China. Together, the defendants and others conspired to systematically divert the U.S. Manufacturer’s servers with certain GPUs to China without a license to do so from the U.S. Department of Commerce.
The scheme operated as follows. Liaw and Chang, who worked closely with third-party brokers with customers based in China, directed certain executives of a company based in Southeast Asia (“Company-1”) to place purchase orders with the U.S. Manufacturer for servers with certain GPUs, purportedly for Company-1. Those servers were often assembled in the United States and shipped to the U.S. Manufacturer’s facilities in Taiwan, then delivered to Company-1 elsewhere in Southeast Asia. Company-1, in consultation with the defendants, then used a shipping and logistics company to repackage the U.S. Manufacturer’s servers and place them in unmarked boxes to conceal their content prior to shipping them to their final destinations in China. To ensure that these server allocations were approved internally at the U.S. Manufacturer, the defendants and executives at Company-1 prepared false documents and records, and transmitted false communications, purporting to show that Company-1 was the end user of the servers.
The defendants and their co-conspirators took extensive measures to conceal their scheme. As just one example, to deceive the U.S. Manufacturer’s compliance team, responsible for ensuring adherence to U.S. export control laws, the defendants staged thousands of “dummy” servers—non-working, physical replicas of the U.S. Manufacturer’s servers—for inspection at the locations where Company-1 was purportedly storing the servers it had purchased from the U.S. Manufacturer. However, the actual servers purchased by Company-1 from the U.S. Manufacturer had already been unlawfully shipped to China.
See our article on this topic at: The Compliance Illusion – FD Associates, Inc.
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March 20, 2026: The Department of Justice announced the former Chief Executive Officer of Nodus International Bank (Nodus Bank), a Puerto Rican international bank, plead guilty on March 19, 2026 for leading a scheme to fraudulently obtain at least $24.9 million from Nodus Bank and conspiring to evade U.S. sanctions against Venezuela.
“This defendant used his position as CEO to siphon more than $24 million, hide conflicts of interest, and help drive the bank’s collapse,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “The scheme also involved efforts to evade U.S. sanctions tied to Venezuela’s state-owned oil company, PDVSA. As a career prosecutor and former state trial judge, I’ve learned that following the money reveals the truth. Here, it exposed both fraud and sanctions violations. We will hold accountable anyone who abuses our financial system for personal gain.”
Tomás Niembro Concha, 64, of Miami, Florida, conspired with others to siphon money from Nodus Bank, ultimately leading to the bank’s failure in 2023. Niembro and his co-conspirators concealed from other Nodus Bank board members and executives and the bank’s regulator that certain investments and loans were for the benefit of Niembro and Board Chairman Juan Ramirez, in violation of Puerto Rican law. From 2017 to 2023, Niembro, Ramirez and others caused Nodus Bank to invest $11 million in a Miami-based lender so those funds could be loaned to Niembro and Ramirez for their own benefit. Niembro and his co-conspirators knew that these transactions were illegal and concealed their conduct through the sham investments.
Between January 2018 and September 2021, Niembro and Ramirez also fraudulently induced Nodus Bank’s board and comptroller to agree to buy at least 47 promissory notes totaling approximately $25.3 million from Nodus Finance, a Miami-based company that Niembro and Ramirez jointly owned, so they could use the proceeds of the transactions for themselves.
In early March 2023, Nodus’s regulator, the Office of the Commissioner of Financial Institutions of Puerto Rico (OCIF), notified the bank it would be placed into liquidation. Niembro and Ramirez fraudulently caused Nodus Bank to accept a loan portfolio from Nodus Finance to pay down the debt from the 47 promissory notes.
Moreover, between 2021 and 2023, Niembro conspired with others to conduct prohibited financial transactions with an individual designated as a Specially Designated National (SDN) by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for providing material support to Venezuela’s state-owned oil company, Petróleos de Venezuela, S.A. (PDVSA). To satisfy an outstanding loan of approximately $2.5 million that the SDN’s company had with Nodus Bank prior to the imposition of sanctions, Niembro and the SDN devised a scheme to cause Nodus Bank to foreclose on the SDN’s home in Southampton, NY — for which they obtained OFAC authorization — but separately reached a “private” agreement to induce Nodus Bank to sell the property back to the SDN for $4 million through a front company — a transaction that was strictly prohibited by U.S. sanctions and not otherwise licensed by OFAC.
Niembro pleaded guilty to a two-count Information charging conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (IEEPA). Each charge carries a maximum penalty of 20 years in prison. Niembro’s sentencing has been scheduled for June 8. As part of his plea agreement, Niembro agreed to forfeit at least $16.9 million, which represents the value of the proceeds he derived from the wire fraud conspiracy. A federal judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.
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March 25, 2026: The Department of Justice charged Stanley Yi Zheng, Matthew Kelly, and Tommy Shad English with conspiring to commit smuggling and export control violations. The three defendants are alleged to have sought millions of dollars’ worth of export-controlled computer chips from a California-based computer hardware company for illegal shipment to China through Thailand.
“Zheng, Kelly, and English allegedly conspired to sell millions of dollars’ worth of American-made AI computer chips to buyers in China, in clear violation of U.S. export controls,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “As our foreign adversaries escalate their efforts to dominate the field of artificial intelligence, we are seeing them employ increasingly brazen schemes to illegally acquire valuable U.S. technology. Enforcing export controls is critical to our work safeguarding America’s economic and national security, and the FBI will continue working with our partners to protect our nation’s innovation and hold accountable those seeking to profit by supplying hostile nation states.”
According to the criminal complaints and other information presented in court: In or about May 2023, Zheng, Kelly, and English began conspiring together to obtain computer servers with export-controlled computer chips from a California-based computer hardware company (Company-1) and ship them to Thailand with an ultimate destination of China, in violation of U.S. law. In doing so, the three defendants used the names of Thailand-based companies as the purported purchasers of the computer servers when in fact the co-conspirators intended for the U.S.-origin AI chips to be diverted to China.
In Oct. 2023, English, purporting to act on behalf of a Thailand-based company, ordered 750 computer servers for approximately $170 million from Company-1. Of the 750 computer servers, 600 contained a computer chip that was controlled on the U.S. Commerce Control List and required a license for export to China. In placing that order, English signed an “Advanced Computing Certification,” certifying that the computer servers were not destined for China or any other country subject to heightened export requirements.
In Jan. 2024, English transferred over $20 million to Company-1 as partial payment for the Oct. 2023 order. In Jan. 2024, when discussing via email an upcoming compliance review for the Oct. 2023 order, English asked Company-1 to add Zheng and Kelly to the email thread, which prompted a response from Company-1 noting, among other things, that Zheng’s company was based in China and that it was “odd” that no one from the Thailand-based company was in the list of carbon copy recipients. Company-1 also commented that “China is an embargoed country restricted by the US government. US companies are restricted from selling to businesses or end users headquartered in China.”
In early Feb. 2024, additional review of the Oct. 2023 order was conducted by the California-based manufacturer of the computer chips that would be inside 600 of the servers English had ordered (Company-2). Company-2’s efforts to verify the end user of the computer chips in Thailand were unsuccessful. Ultimately, the Oct. 2023 purchase was not completed.
While the Oct. 2023 deal lost momentum, in April 2024, English, purporting to act on behalf of a second Thailand-based company, sought to order from Company-1 another 500 computer servers that contained an export-controlled computer chip. In doing so, English signed an End User Certification stating that the Thailand-based company was the end user for the purchase. This deal, like the Oct. 2023 deal, ultimately was unsuccessful.
Text messages obtained through the investigation illustrated aspects of the conspiracy and revealed that Zheng, English, and Kelly discussed, among other things, “fake” corporate niceties to help complete the computer chip purchases, the value of the computer chips in China, and recruitment of others to participate in the scheme.
This case is being investigated by the Department of Commerce’s Bureau of Industry & Security, the Defense Criminal Investigative Service, Homeland Security Investigations, and the Federal Bureau of Investigation as the result of a tip that BIS received through an email account listed on the BIS website.
Assistant U.S. Attorney Samir Kaushal of the United States Attorney’s Office for the Northern District of Georgia and Trial Attorney Brett Ruff of the National Security Division’s Counterintelligence and Export Control Section are prosecuting the case.
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March 30, 2026: Manfred Gruber, an Italian national, plead guilty to conspiracy to commit export control violations. Gruber illegally exported ammunition worth over $540,000 from the United States to Kyrgyzstan, via companies that the defendant and his co-conspirator controlled in Italy. After reaching Kyrgyzstan, most of this ammunition was subsequently reexported to Russia.
In January 2026, Sergei Zharnovnikov, a Kyrgyzstan-based co-conspirator of the defendant, was sentenced to 39 months’ imprisonment after pleading guilty to violating the Export Control Reform Act.
“Manfred Gruber put many lives at risk by illegally supplying Russia with hundreds of thousands of dollars’ worth of American-made, military-grade ammunition to advance its war in Ukraine,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division.
“The defendant used multiple companies to hide his scheme to send military‑grade ammunition to Kyrgyzstan, before it was reexported to Russia to support its war effort,” stated United States Attorney Joseph Nocella for the Eastern District of New York. “I commend our partners at the FBI and the Department of Commerce for uncovering this deadly scheme and swiftly bringing Gruber to justice.”
Sanctions
Department of Commerce, Bureau of Industry & Security
March 31, 2026: 91 Fed. Reg. 15948: The Department of Commerce, Bureau of Industry & Security issued an order renewing temporary denial of export privileges of Aviastar – TU (”Aviastar”).
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for March 1 through March 31, 2026.
- OFAC issued 10 new/amended General Licenses and 13 new Frequently Asked Questions related to Venezuela Sanctions.
- OFAC issued 5 new General Licenses and 2 new Frequently Asked Questions related to Russia Sanctions.
- OFAC issued 1 new General License related to Belarus Sanctions.
- OFAC issued 1 new General License related to Iran Sanctions.
- OFAC issued 1 new General License related to the sanctioning of the Rwanda Defence Force.
- OFAC issued Guidance on Sham Transactions and Sanctions Evasion.
- OFAC added to the Specially Designated Nationals List individual and entities from:
- Rwanda, notably the Rwanda Defence Force, for supporting human rights abuse in the Democratic Republic of the Congo;
- Sudan as a result of recent designation as a Foreign Terrorist Organization;
- Turkey and Indonesia as a result of being designated as sham organizations that directly fund Hamas, a Foreign Terrorist Organization;
- N. Korea because they systematically defrauded U.S. persons to fund N. Korea’s Weapons of Mass Destruction Programs;
- Canada, Lebanon, Poland, Slovenia, and Syria for laundering and raising funds for Hizballah, a Foreign Terrorist Organization.
Detailed information regarding the OFAC can be found at https://ofac.treasury.gov/recent-actions.