This newsletter is a listing of the latest changes in export control regulations through April 30, 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.
REGULATORY UPDATES
President
Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Domestic Petroleum Production, Refining, and Logistics Capacity
April 20, 2026: 91 Fed Reg. 21933: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) domestic petroleum production, refining, and logistics capacity, including exploration and production, gathering and transmission pipelines, storage, and marine terminals, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology item in a timely manner due to constrained financing, long lead times, permitting and infrastructure bottlenecks, and supply chain limitations; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand the domestic petroleum production, refining, and logistics capacity is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08016.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Coal Supply Chains and Baseload Power Generation Capacity
April 20, 2026: 91 Fed. Reg. 21927: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) coal supply chains and baseload power generation capacity, including coal mining, rail and barge logistics, export and domestic terminals, generating unit availability and life-extension work, on-site stockpiles, and associated reliability updates, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology item in a timely manner due to financing constraints, regulatory delays, long-lead maintenance, expensive and bespoke repair cycles, and market barriers; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand coal supply chain capacity and baseload generation availability is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08010.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Natural Gas Transmission, Processing, Storage, and Liquefied Natural Gas Capacity
April 20, 2026: 91 Fed. Reg. 21935: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) natural gas and LNG capacity, including gathering and transmission pipelines, compression, processing plants, underground storage, LNG liquefaction, storage and marine load, export facilities, and critical distribution infrastructure, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology item in a timely manner due to financing constraints, long-lead equipment and construction schedules, permitting delays, and infrastructure bottlenecks; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand domestic natural gas transmission, processing, storage, and LNG capacity is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08017.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Development, Manufacturing, and Deployment of Large-Scale Energy and Energy Related Infrastructure
April 20, 2026: 91 Fed. Reg. 21929: The President determine, pursuant to section 303(a)(5) of the Act, that:
(1) development, manufacturing, and deployment of large-scale energy and energy-related infrastructure, including engineering, site acquisition and preparation, permitting, early-stage risk mitigation financing instruments, domestic manufacturing capacity, and enabling infrastructure, are industrial resources, materials, and critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology items in a timely manner due to financing risks, regulatory delays, and market barriers; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand the domestic capability to undertake development, manufacturing, and deployment of large-scale energy and energy-related infrastructure is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08011.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Grid Infrastructure, Equipment, and Supply Chain Capacity
April 20, 2026: 91 Fed. Reg. 21931: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) grid infrastructure and its associated upstream supply chains, including transformers, transmission lines and conductors, substations, high-voltage circuit breakers, power control electronics, protective relay systems, capacitor banks, electrical core steel, and related raw materials and manufacturing tools, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology items in a timely manner due to limited domestic production capacity, extended procurement timelines, foreign supply dependence, and insufficient capital investment; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determine that action to expand the domestic capability to develop, manufacture, and deploy grid infrastructure and supporting industrial supply chains is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, The President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08013.pdf
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Department of State, Directorate of Defense Trade Controls (DDTC)
60-Day Notice of Proposed Information Collection: Brokering Prior Approval (License)
April 6, 2026: 91 Fed. Reg. 17323: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collection to OMB.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=64ac35fc971c07580083b3b0f053af56
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60-Day Notice of Proposed Information Collection: Annual Brokering Report
April 6, 2026: 91 Fed. Reg. 17324: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the
collection to OMB.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=e4acb1fc971c07580083b3b0f053af6b
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60-Day Notice of Proposed Information Collection: Disclosure of Violations of the Arms Export Control Act
April 7, 2026: 91 Fed. Reg. 17669: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=64ac35fc971c07580083b3b0f053af5a
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IMPORTANT: DECCS Registration Enhancements April 30, 2026
April 27, 2026: DDTC updated the DECCS Registration application on Wednesday, April 30, 2026 and introduced new features including:
- Enhanced validation for articles and documents
- Improved management of senior officers and points of contact
- Better compliance tracking
- Additional safeguards to prevent accidental amendment submissions
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DDTC Name And Address Changes Posted To Website
April 1, 2026, through April 30, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Honeywell International Inc. subsidiaries that fall within the Honeywell Aerospace Technologies division changed their name and address due to corporate restructuring.
- From: Honeywell Limited / Honeywell Limitee Address: 3333 Unity Drive, Mississauga, Ontario L5L 3S6 Canada
To: Honeywell Aerospace International Inc. Address: 3333 Unity Drive, Mississauga, Ontario L5L 3S6 Canada
- From: Honeywell Limited Address: Level 2, 2 Richardson Place North Ryde, NSW 2113, Australia
To: Honeywell Aerospace Australia Pty. Ltd. Address: Suite 301A, 25 Montpelier Road, Bowen Hills, Queensland 4006 Australia - From: Honeywell do Brasil Ltda. Address: Avenida Tambore, 267, Edificio Canopus Corporate Alphaville, 16 e 17 andares, Sao Paulo, Barueri, CEP –6460-000 Brazil
To: Honeywell Aeroespacial do Brasil Ltda. Address: Avenida Brigadeiro Faria Lima, 2170, salas 16, 17 e 18. Predio F-65, Sao Paulo State, Jao Jose dos Campos City, Brazil - From: Honeywell Chile S.A. Address: El Bosque 500, 8th Floor, Las Condes, Santiago Chile
To: Honeywell Aerospacial Chile S.p.A Address: Avenida el Bosque Norte 500 Piso 8, RM, Santiago, 750-0007, Chile - From: Honeywell Colombia S.A.S. Address: Carrera 11, #98-50, Edifico Punto 99, Piso 7, Bogota, Capital District, Colombia
To: Honeywell Aerospace Colombia S.A.S. Address: Carrera 11, #98-50, Edifico Punto 99, Piso 7, Bogota, Capital District, Colombia
- From: Honeywell spol. S.r.o. Address: V Parku 2325/16, Praha, 14800, Czech Republic
To: Honeywell International s.r.o. Address: V Parku 2325/16, Praha, 14800, Czech Republic
- From: PT Honeywell Indonesia Address: 24th Floor Menara Prima, Unit E, Jl. Dr. Ide Anak Agung Gde Agung Blok 6.2, Kawasan Mega Kuningan, Jakarta, 12950, Indonesia
To: PT Honeywell Aerospace Indonesia Address: Sopo Del Tower B, 22nd Floor, JL. Mega Kuningan Barat III Lot 10. 1-6, Kuningan, South Jakarta, Jakarta 12950 - From: Japan Honeywell GK Address: 16-1, Kaigan 1-chome, Minato-ku, Tokyo, Japan, 105-0022, Tokyo, Japan
To: Honeywell Aerospace Japan GK Address: 1-6, Motoazabu 3-chome, Minatoku, Tokyo, Japan
- From: Honeywell International Sdn. Bhd. Address: Level 25, UOA Corp Tower Lobby B, Avenue 10, The Vertical, Bangsar South City, Kuala Lumpur, 59200, Malaysia
To: Honeywell Aerospace Malaysia Sdn. Bhd. Address: Suite 1005, 10th Floor, Wisma Hamzah Keonh Hing, No. 1 Leboh Ampang 50100 Kuala Lumpur W.P. Kuala Lumpur Malaysia
- From: Honeywell Automotive de Mexico S. de R. L. de C.V. Address: Av Salvador Nava Martinez 3125, Piso 6 Colinas Del Parque, San Luis Potosi, San Luis Potosi, 78260, Mexico
To: Honeywell Aerospace de México, S. de R.L. de C.V. Address: Circuito Aeroespacial Lote 2, Parque Industrial El Vigia, Mexicali, Baja California, 21397, Mexico - From: Honeywell Sp. Z.o.o. Address: Domaniewska 39, Warsaw, 02672, Poland
To: Honeywell Services Poland Sp Z.o.o. Address: ul. Zelazna 4, Katowice, 40-851, Poland - From: Honeywell S.L. Address: María de Portugal, 1-5, Building 3, Madrid, 28050, Spain
To: Honeywell Aerospace Spain S.L. Address: 39, Paseo de la Castellana, Madrid, 28046, Spain - From: Honeywell Taiwan Limited Address: 5F, No.3, Yuandong Road, Banqiao District, New Taipei City, Taiwan (Province of China)
To: Honeywell Aerospace Taiwan Ltd Address: 8F. No.560 Sec.4 Zhongxiao E. Rd. Xinyi Dist. Taipei City 110 Taiwan(R.O.C.)
- From: Honeywell Teknoloji Anonim Sirketi Address: Küçükbakkalköy Mah., Kayisdagi Ca d. No:1, Allianz Plaza Kat:27, Atasehir, Istanbul, 34750, Turkey
To: Honeywell Aerospace Turkey Havacılık ve Uzay Sanayii Limite d Sirketi Address: Şirketi Allianz Plaza Sitesi D:27, Kucukbakkalkoy Mah. Kayisdagi Cad, No:1, Allianz Plaza Kat:27 Atasehir, Istanbul, 34751, Turkey
- MDA Systems Ltd. changed its name to MDA Space 49North Ltd. due to a corporate restructuring.
- Keysight Technologies Denmark ApS changed its address from Alfred Nobels VEJ 21, Aalborg East 9220, Denmark to Alfred Nobels VEJ 21F, Aalborg East DK-9220 Denmark.
- Enterprise Services Defence and Security UK Ltd., Entserv UK Limited, and ES Field Delivery UK Limited (collectively referred to as “DXC UK entities”) changed their address as follows: DXC UK entities, Royal Pavillion, Wellesley Road, Aldershot, United Kingdom GU11 1PZ to 110 Pinehurst Road, Farnborough Business Park, Farnborough, United Kingdom, GU14 7BF.
- Computer Sciences Limited was added to DXC UK entities as a new subsidiary
- ispace, inc. changed its address from Sumitomo Fudosan Hamacho Building 3F, 3-42-3 Nihonbashi Honcho, Chuo-ku, Tokyo, Japan 103-0007 to Nihonbashi Honcho M-SQUARE 6F, 1-9-3 Nihonbashi Honcho, Chuo-ku, Tokyo, Japan 103- 0023.
- Metrea Management, LLC’s Swedish and Australian affiliates changed their addresses due to corporate restructuring.
- Metrea Simulations AB, Sweden
From: Luntmakargatan 66, 113 51 Stockholm, Sweden
To: Luntmakargatan 34, 111 37, Stockholm, Sweden
- Metrea Australia Solution 1 Pty Ltd and Metrea Australia Assets Pty 1 Ltd Metrea Australia Pty Ltd
From: Director’s Vault 6/46 Washington Street, Toorak Victoria, Australia
To: Suite 2.03, Part Level 2, 220 St George Terrace, Perth WA, 6000, Australia
- MDA Systems Ltd. transferred its’ business to MDA Space 49North Ltd., a separate, wholly-owned subsidiary of MDA Systems Ltd, due to corporate restructuring.
- Wescam USA, Inc. changed its address from 2410 North Orange Blossom Trail, Orlando, FL 32804 to 2204 Charlotte Ave., Building C, Nashville, TN 37203.
- Pacific Aerospace Consulting Pty Ltd (PAC) was acquired by Aurizn Bidco Pty Ltd, wholly owned by Aurizn Holdco Pty Ltd, and changed its address from Suite 111, 460 Pacific Highway, St Leonards NSW 2065 Australia to U2.02 Building E, 1 Technology Place, Willamtown NSW 2318 Australia
- Maxar Intelligence Inc., selected affiliates and foreign subsidiaries, changed their names due to a corporate split and rebranding as follows:
- From Maxar Technologies Inc. to Vantor Parent Inc.;
- From Maxar Technologies Holdings Inc. to Vantor Holdings Inc.;
- From Maxar Intelligence Inc. to Vantor Inc.;
- From Maxar International Inc. to Vantor International Inc.;
- From Maxar Mission Solutions Holdings Inc. to Vantor Services Holdings Inc.;
- Maxar Mission Solutions Inc. to Vantor Services Inc.;
- From Maxar Intelligence 3D Inc. to Vantor 3D Inc.;
- From Wovenware Inc. to Vantor Puerto Rico Inc.;
- From Maxar International Canada Inc. to Vantor Canada Inc.;
- From Maxar International Australia Pty Inc. to Vantor Australia Pty Ltd.;
- From Maxar International Asia Pacific Pte. Ltd. to Vantor Asia Pacific Pte. Ltd.; and
- From Maxar International Great Britain Limited to Vantor Great Britain Limited
- CEVA Freight LLC located at 15350 Vickery Dr., Houston, Texas 77032-2530 transferred its’ business to CEVA Air & Ocean USA Inc. located at 1412 Broadway Ste 402, New York, New York 10018.
Editors practice tip: freight forwarder changes such as noted herein may impact your export license. As with this change and any noted in the DDTC website for name and address changes be sure to include a copy of the DDTC notice which can be pulled down from the attached link with your export license when providing the license to the freight forwarder.
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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.
- Singapore – Guided Multiple Launch Rocket System – Alternative Warhead
https://www.state.gov/singapore-guided-multiple-launch-rocket-system-alternative-warhead/
- Germany- Integrated Combat System, Supporting Equipment, and Support
- The Netherlands – Hellfire Missiles
- Lithuania – AIM-9X Sidewinder Block II Missiles
- Tunisia – Border Security Project Phase III
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Department of Commerce – Bureau of Industry and Security (BIS)
BIS published a rule titled “Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits; Amendments and Clarifications; and Extension of Comment Period”
April 9, 2026: 91 Fed. Reg. 17851: On January 16, 2025, BIS published a rule titled “Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits; Amendments and Clarifications; and Extension of Comment Period”, which included a timeline during which certain companies are considered authorized integrated circuit (IC) designers who can overcome a presumption of certain license requirements. On April 7, 2026, BIS extended this timeline until December 31, 2026. This extension will allow more time for companies to submit Approved IC Designer applications and allow BIS additional time to process these applications.
https://www.govinfo.gov/content/pkg/FR-2026-04-09/pdf/2026-06851.pdf
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American AI Exports Program; Call for Proposals for Pre-Set Consortia
April 10, 2026: 91 Fed. Reg. 18412: The Department of Commerce, International Trade Administration invites proposals for full-stack American AI export packages from industry-led `pre-set’ consortia for designation under the American Artificial Intelligence (AI) Exports Program (the Program) established pursuant to Executive Order 14320, “Promoting the Export of the American AI Technology Stack.” A designated package will be presented by U.S. Government representatives as a standing, full-stack American AI export package and may receive priority government advocacy, export licensing review and processing, interagency coordination, and financing referrals, subject to applicable law. Designation does not guarantee any particular form of federal assistance, financing, license approval, advocacy outcomes, or a contract award.
The call for proposals opens on April 1, 2026 and proposals will be accepted until 5:00 p.m. Eastern Daylight Time on June 30, 2026.
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Eliminating Outdated Regulation Related to Reports on Exports of Technology
April 17, 2026: 91 Fed. Reg. 20582: The Department of Commerce eliminated 15 CFR Part 1300, an outdated regulation related to reports on exports of technology. The cited statutory basis for the regulation has been repealed, and its contents are plainly obsolete and pose a genuine risk of confusion. This action is necessary to ensure that the Department’s body of regulations remains accurate, up-to-date, and in conformity with statutory law.
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
March 27, 2026: The Department of Commerce’s Bureau of Industry & Security (“BIS”) reached a settlement with Solventum Corporation, under which the company agreed to pay $1,600,000 for two violations of the EAR.
The two violations involved the unlicensed exports of EAR99 Liqui-Cel Membrane Contactors (“Contactors”) to Semiconductor Manufacturing South China Corporation (“SMIC South”) and Ningbo Semiconductor International Corporation (“NSI”). Both companies are identified on the Entity List and required a license for the export, reexport, or transfer (in-country) for all items subject to the EAR.
https://www.bis.gov/media/documents/settlement-agreement-solventum.pdf
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April 8, 2026: The Department of Justice announced the arrest of Courtney Williams, a former Army employee, and a federal grand jury indictment in connection with her alleged transmission of classified national defense information to individuals not authorized to receive it, including a journalist (the Journalist). Williams allegedly violated 18 U.S.C. § 793(d).
From 2010 to 2016, Williams worked for a Special Military Unit (SMU) and held a Top Secret / Sensitive Compartmented Information security clearance. In her role at the SMU, Williams had daily access to a broad range of classified information.
Between 2022 and 2025, Williams repeatedly communicated with a journalist via telephone and text messages. During this period, Williams and the journalist had over 10 hours of telephone calls and exchanged more than 180 messages. In one such message, the Journalist identified themselves as a journalist and stated that they sought information about the SMU in support of an upcoming article and book. After these communications with Williams, the Journalist published a book and article that named Williams as a source and attributed specific statements to her. Some of these statements contained classified national defense information. In addition to her disclosures to the Journalist, Williams also made unauthorized disclosures of national defense information via her social media accounts that included details about the SMU structure, capabilities and internal workings.
“Courtney Williams swore an oath to safeguard our nation’s secrets as an employee supporting a Special Military Unit of the Army, but she allegedly betrayed that oath by sharing classified information with a media outlet and putting our nation, our warfighters, and our allies at risk,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “This indictment should serve as a stark warning to all current and former clearance holders thinking of violating their positions of trust. If you jeopardize our national security by disclosing classified information without authorization, the FBI will hold you accountable for your crimes.”
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April 14, 2026: The Department of Commerce’s Bureau of Industry & Security (“BIS”) reached a settlement with Coastal PVA Technology, Inc., under which the company agreed to pay $1,700,000 for eighteen violations of the EAR.
The violations involved the export of polyvinyl alcohol (“PVA”) brushes, between May 2021 and May 2024, to Semiconductor Manufacturing International (Beijing) Corporation (“SMIC Beijing”), and Semiconductor Manufacturing North China (Beijing) Corporation (“SMIC North”). At the time of exports via two third-party distributors, both SMIC Beijing and SMIC North were identified on the Entity List.
https://www.bis.gov/media/documents/coastal-pva-technology-final-order-4-13-2026.pdf
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April 15, 2026: The Justice Department announced the sentencings of two U.S. nationals, Kejia Wang, 42, and Zhenxing Wang, 39, for their roles in facilitating North Korean remote information technology (IT) workers posing as U.S. residents to obtain work at more than 100 U.S. companies. The multi-year scheme used the stolen identities of at least 80 U.S. persons and generated more than $5 million in illicit revenue for the government of the Democratic People’s Republic of Korea (DPRK).
From approximately 2021 until October 2024, the defendants and their co-conspirators compromised the identities of more than 80 U.S. persons to obtain remote jobs at more than 100 U.S. companies, including many Fortune 500 companies, and caused U.S. victim companies to incur legal fees, computer network remediation costs, and other damages of at least $3 million.
Kejia Wang, Zhenxing Wang and at least five facilitators in the United States received and hosted victim company laptops at their residences and enabled overseas IT workers to access the laptops remotely by, among other things, connecting the laptops to hardware devices designed to allow for remote access (referred to as keyboard-video-mouse or “KVM” switches).
Kejia Wang and Zhenxing Wang created shell companies with corresponding financial accounts, including Hopana Tech LLC, Tony WKJ LLC, and Independent Lab LLC, to make it appear as though the overseas IT workers were affiliated with legitimate U.S. businesses. In fact, these companies had no employees or operations and existed only to further the scheme and enable the defendants and their co-conspirators to receive proceeds from the scheme. These shell companies ultimately received more than $ 5 million dollars from victimized U.S. companies, much of which was subsequently transferred to overseas co-conspirators.
In addition to the defrauding of the companies, the IT workers employed under this scheme also gained access to sensitive employer data and source code, including International Traffic in Arms Regulations (ITAR) data from a California-based defense contractor that develops artificial intelligence-powered equipment and technologies. Specifically, between on or about January 19, 2024, and on or about April 2, 2024, an overseas co-conspirator remotely accessed without authorization the company’s laptop and computer files containing technical data and other information. The stolen data included information marked as being controlled under the ITAR.
Kejia Wang, of Edison, New Jersey, was sentenced to 108 months in prison for conspiracy to commit wire fraud, conspiracy to commit money laundering, and conspiracy to commit identity theft. Zhenxing Wang, of New Brunswick, New Jersey, was sentenced to 92 months for conspiracy to commit wire fraud and conspiracy to commit money laundering. In addition to the sentences of imprisonment, U.S. District Court Judge Nathaniel M. Gorton ordered the defendants to serve three years each of supervised release and to forfeit a total of $600,000 that was paid to them for facilitating the North Koreans. As of today, the United States has already received $400,000 of the ordered forfeiture amount. The court also ordered Kejia Wang to pay a judgment of $29,236.03 in restitution.
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April 17, 2026: The Department of State’s DDTC posted its consent agreement with General Electric Company (“GE”) alleging it violated the International Traffic in Arms Regulations (ITAR). The consent agreement imposed a $36 million fine and the appointment of a Special Compliance Officer for three years to oversee the implementation of corrective actions.
DDTC charged GE with 116 violations of the ITAR that occurred between April 17, 2018 and November 17, 2024. GE submitted 12 voluntary disclosures to DDTC between August 2019 and December 2024 reporting the violations.
The violations are related to USML Categories IV, I, VIII, XII, and XIX and involved:
- Unauthorized exports of USML Categories VIII(i) and XIX(g) technical data related to electrical power generation for the F-35 aircraft and the F414 military aircraft engine to the People’s Republic of China (PRC);
- Failure to manage DDTC authorizations properly;
- GE’s failed to properly validate the parties’ role in the transaction which resulted in the transfer of hardware or technical data to unauthorized end users and sublicensees.
- GE did not comply with provisos of a Technical Assistance Agreement and DSP-5 licenses.
- Unauthorized exports of USML Category XIX(f)(2) combustion liner designed for the F404-400 military aircraft engine to Sweden and USML Category VIII(h)(1) machined chassis specially designed for the F-35 aircraft to Israel; and
- Failure to report material changes to Respondent’s DDTC registration.
To correct deficiencies with its policies, procedures, and controls GE is to appoint, subject to the approval of DDTC, a SCO who will oversee implementation of the corrective actions. GE will, among other things:
- Ensure adequate resources are dedicated to ITAR compliance throughout the organization;
- Establish policies and procedures within the specified timelines;
- Implement a comprehensive automated export compliance system across the organization to improve oversight and control of exports, reexports, and transfers of technical data and hardware and the provision defense services;
- Perform a classification review to validate the export jurisdiction and classification of hardware, technical data, software, and defense services; and
- Perform at least one audit during the term of the consent agreement.
The Charging Letter, Agreement and the Order are attached.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=0bfa21fd97100f980083b3b0f053af9f
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=07faedbd97100f980083b3b0f053af14
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=cbfaedbd97100f980083b3b0f053af19
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April 23, 2026: The Department of Justice announced that Tianrui Liang, 21, of China, has been charged by complaint for conduct related to illegally documenting Air Force planes located at Offutt Air Force Base in Bellevue, Nebraska.
Offutt Air Force Base is a key base in the Air Force’s Strategic Command and is the home of Command-and-Control, reconnaissance and strategic support aircraft.
“Any individuals who unlawfully attempt to acquire sensitive information about military aircraft located in the District of Nebraska will be held maximumly accountable under federal law,” said U.S. Attorney Lesley Woods.
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April 23, 2026: The Department of Justice announced an indictment charging Gannon Ken Van Dyke, a U.S. Army soldier, with unlawful use of confidential government information for personal gain, theft of nonpublic government information, commodities fraud, wire fraud, and making an unlawful monetary transaction. The charges arise from an alleged scheme in which Van Dyke used sensitive classified information to make wagers on Polymarket, a prediction marketplace. As alleged in the indictment, Van Dyke participated in the planning and execution of the U.S. military operation to capture Nicolás Maduro, called “Operation Absolute Resolve,” and Van Dyke used his access to classified information about that operation to personally profit.
Van Dyke was involved in the planning and execution of Operation Absolute Resolve, a military operation to capture Maduro, and had access to sensitive, nonpublic, classified information about that operation.
On or about Dec. 26, 2025, Van Dyke created a Polymarket account, funded it, and began trading on Maduro- and Venezuela-related markets. In total, Van Dyke made approximately 13 bets from Dec. 27, 2025, through the evening of Jan. 26. Those bets all took the “YES” position on “U.S. Forces in Venezuela . . . by January 31, 2026”; “Maduro out by . . . January 31, 2026”; “Will the U.S. invade Venezuela by . . . January 31,”; or “Trump invokes War Powers against Venezuela by . . . January 31.” Van Dyke bet a total of approximately $33,034 on those outcomes while in possession of classified nonpublic information about Operation Absolute Resolve.
As a result of his access to classified information, Van Dyke won his wagers on those contracts. In total, Van Dyke allegedly profited approximately $409,881.
“Gannon Ken Van Dyke allegedly betrayed his fellow soldiers by utilizing classified information for his own financial gain,” said FBI Assistant Director in Charge James C. Barnacle Jr. “Van Dyke profited more than $400,000 by trading various outcomes related to Venezuela after learning of the operation because of his role as a U.S. Army soldier.
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for April 1 through April 30, 2026.
- Treasury Proposes Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance
https://ofac.treasury.gov/recent-actions/20260408_33
- Issuance of Amended Russia-related General License and Frequently Asked Questions; Publication of Spanish Translations of Venezuela-related General Licenses and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260408
- Venezuela-related Designation Removal; Issuance of Venezuela-related General Licenses and Frequently Asked Question; Publication of Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act (TSRA)
https://ofac.treasury.gov/recent-actions/20260414_33
- Counter Narcotics, Counter Terrorism Designations; Issuance of Related General License; Issuance of Amended Russia-related General Licenses and Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260414
- Iran-related Designations; Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260415
- Nicaragua-related Designations; Issuance of Nicaragua-related General License https://ofac.treasury.gov/recent-actions/20260416
- Counter Terrorism Designations; Sudan Designations
https://ofac.treasury.gov/recent-actions/20260417
- Counter Terrorism, Counter Narcotics, and Cyber-related Designations; Issuance of Cyber-related General License
https://ofac.treasury.gov/recent-actions/20260423
- Iran-related Designations; Counter Terrorism and Iran-related Designation Update; Issuance of Iran-related General License
https://ofac.treasury.gov/recent-actions/20260424
- Counter Terrorism Designation; Iran-related Designations; Issuance of Frequently Asked Question; Publication of Iran-related OFAC Alert
https://ofac.treasury.gov/recent-actions/20260428
- Issuance of Amended Russia-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260429
- Democratic Republic of the Congo-related Designation
