This newsletter is a listing of the latest changes in export control regulations through April 30, 2025. 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
The President Announces Executive Order to Reform Foreign Defense Sales To Improve Speed and Accountability
April 9, 2025: To serve the interests of the American people, the United States must maintain the world’s strongest and most technologically advanced military through a dynamic defense industrial base, coupled with a robust network of capable partners and allies. A rapid and transparent foreign defense sales system that enables effective defense cooperation between the United States and our chosen partners is foundational to these objectives. Reforming this system would simultaneously strengthen the security capabilities of our allies and invigorate our own defense industrial base. This mutually reinforcing approach would enhance United States warfighting capabilities by fostering healthy American supply chains, domestic production levels, and technological development.
Sec. 2. Policy. It is the policy of the President’s Administration to:
(a) Improve accountability and transparency throughout the foreign defense sales system to ensure predictable and reliable delivery of American products to foreign partners in support of United States foreign policy objectives.
(b) Consolidate parallel decision-making when determining which military capabilities the United States will choose to provide, and to which countries.
(c) Reduce rules and regulations involved in the development, execution, and monitoring of foreign defense sales and of transfer cases to ensure alignment with United States foreign policy objectives.
(d) Increase government-industry collaboration to achieve cost and schedule efficiencies in the execution of the Foreign Military Sales (FMS) program.
(e) Advance United States competitiveness abroad, revitalize the defense industrial base, and lower unit costs for the United States and our allies and partners by integrating exportability features in the design phase, improving financing options for partners, and increasing contract flexibility overall.
Sec. 3. Phased Implementation.
(a) The Secretary of State and the Secretary of Defense shall promptly:
(i) Implement National Security Presidential Memorandum 10 of April 19, 2018 (United States Conventional Arms Transfer Policy), or any successor policy directive.
(ii) Reevaluate restrictions imposed by the Missile Technology Control Regime on Category I items and consider supplying certain partners with specific Category I items, in consultation with the Secretary of Commerce.
(iii) Submit a joint letter to the Congress proposing an update to statutory congressional certification (also known as congressional notification) thresholds of proposed sales under the FMS and Direct Commercial Sales (DCS) programs in the Arms Export Control Act (22 U.S.C. 2751 et seq.). The Secretary of State shall also work with the Congress to review congressional notification processes to ensure the timely adjudication of notified FMS and DCS cases.
(b) Within 60 days of the date of this order:
(i) The Secretary of State, in consultation with the Secretary of Defense, shall develop a list of priority partners for conventional arms transfers and issue updated guidance to Chiefs of the United States Diplomatic Missions regarding this list.
(ii) The Secretary of Defense, in consultation with the Secretary of State, shall:
(A) develop a list of priority end-items for potential transfer to priority partners identified by the Secretary of State in the list required by this subsection;
(B) ensure the transfer of priority end-items to priority partners would not cause significant harm to United States force readiness; and
(C) ensure the transfer of priority end-items to priority partners would advance my Administration’s goal of strengthening allied burden-sharing, both by sharing the cost of end-item production and by increasing our allies’ capacity to meet capability targets independently, without sustained support from the United States.
(c)(i) The Secretary of State and the Secretary of Defense shall review, update, and reissue the lists of priority partners and military end-items on an annual basis. The United States Munitions List, 22 C.F.R. part 121, to focus protections solely on our most sensitive and sophisticated technologies and shall establish clear criteria for including an item on the FMS-Only List.
(c)(ii) The Secretary of State and the Secretary of Defense shall review and update the list of defense items that can only be purchased through the FMS process (the FMS-Only List) and the United States Munitions List, 22 C.F.R. part 121, to focus protections solely on our most sensitive and sophisticated technologies, and shall establish clear criteria for including an item on the FMS-Only List.
(d) Within 90 days of the date of this order, the Secretary of State and the Secretary of Defense, in consultation with the Secretary of Commerce, shall submit a plan to the President, through the Assistant to the President for National Security Affairs (APNSA), to: improve the transparency of United States defense sales to foreign partners by developing metrics for accountability; secure exportability as a requirement in the early stages of the acquisition process; and consolidate technology security and foreign disclosure approvals.
(e) Within 120 days of the date of this order, the Secretary of Defense, with the assistance of the Secretary of State and the Secretary of Commerce, shall submit a plan to the APNSA to develop a single electronic system to track all DCS export license requests and ongoing FMS efforts throughout the case life-cycle.
Sec. 4. Definitions. For purposes of this order:
(a) “Parallel decision-making” refers to the granting of simultaneous certifications and approvals during the FMS process, as opposed to sequential decision-making where agencies wait for other agencies to make decisions before taking action.
(b) “Exportability” means the process to identify, develop, and integrate technology protection features into United States defense systems early in the acquisition process to protect critical technologies, capabilities, and program information and thus enable export to partners.
(c) “FMS-only” means defense articles that are exclusively available through the FMS process as opposed to the DCS process, as authorized in the Arms Export Control Act and described in the Security Assistance Management Manual (SAMM), Defense Security Cooperation Agency (DSCA), Chapter 4.
(d) “End-item” means the final product when assembled and ready for issue or deployment.
(e) “Foreign defense sales system” means the enterprise devoted to the transfer of defense articles, services, and training by the United States Government and United States companies to international partners and organizations.
(f) All other terms related to FMS cases shall have the meanings given to them by the SAMM, DSCA 5105.38M.
Sec. 5. General Provisions.
(a) Nothing in this order shall be construed to impair or otherwise affect:
(i) the authority granted by law to an executive department or agency, or the head thereof; or
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
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Department of State, Directorate of Defense Trade Controls (DDTC)
Annual Report to Congress on Direct Commercial Sales Authorizations to Foreign Countries and International Organizations for Fiscal Year 2024 as required by Section 655 of the Foreign Assistance Act of 1961, as amended
April 25, 2025: This report documents defense articles and defense services licensed for permanent export under Section 38 of the Arms Export Control Act (AECA), 22 U.S.C. 2778, to each foreign country and international organization during fiscal year (FY) 2024, in response to the requirements in Section 655(b)(3) of the Foreign Assistance Act (FAA) of 1961, as amended. The Department of Defense will report International Military Education and Training activities separately.
The report specifies the aggregate dollar value and quantity of defense articles, and defense services, authorized to each foreign country and international organization during the fiscal year, as well as data on the actual shipments of those licensed transactions. The actual-shipment data shows the total dollar value of all shipments that were authorized and on Page 2 of 4 that exported during the fiscal year to each destination. Authorizations in this report are categorized based on the destination country.
Authorizations applicable to multiple countries in the appendix are included under the designation “Various.” Documentation for shipping purposes requires a definitive destination be declared. Accordingly, actual shipments for those articles approved under the designation “Various” are attributed to the country listed on the shipping documentation.
The reported value of authorizations for defense articles and defense services does not correlate precisely to the value of articles actually transferred during the reporting period. The reasons for this are as follows: Most licenses issued for defense articles are valid for four years and may be used throughout the four years to execute authorized transactions. Similarly, manufacturing license and technical assistance agreements cover a wide range of programmatic activities for multi-year periods (generally exceeding the four-year validity period of defense-article export licenses). Export authorizations furnished in FY 2024 also include certain activities occurring in prior years, because the scope of the Department’s regulatory authority over such agreements continues for as long as these multi-year agreements remain in effect
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=ef6ae6324785aa107ddc0c03e16d43ef
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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DDTC Name And Address Changes Posted To Website
April 1, 2025, through April 30, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in Name of Churyo Engineering Co., Ltd. to MHI Aero Technologies Co., Ltd. due to acquisition;
- Change in Name of Compro Computer Services, Inc. to Aechelon Technology, Inc. due to acquisition;
- Change in Name of Toshiba Infrastructure Systems & Solutions Corporation to Toshiba Corporation due to corporate restructuring;
- Change in Name of Bollore Logistics SE to CEVA Logistics SA due to acquisition;
- Change in Address of Mikuni Aerospace Corporation, Nagoya Sales Office from 1-17-26 Nishiki, Naka-ku, Nagoya, Aichi, Japan to 3-20- 27 Nishiki, Naka-ku, Nagoya, Aichi Prefecture 460-003, Japan;
- Change in Name and Address of General Electric International Inc., Kungsgatan 15, Stockholm, Sweden to Arcam AB, Designvagen 2, Molnlycke 435 33, Sweden due to acquisition;
- Change in Name of Daher Aerospace SA to Daher Logistics SAS and Daher Business Support SAS due to company spin-off;
- Change in Address of OHB Sweden AB, Vidarugatan 6, 164 40 Kista, Sweden to Torshamnsgatan 24, 164 40 Kista, Sweden;
- Change in Address of General Dynamics Mission Systems, Inc. and General Dynamics Mission Systems Overseas Company, LLC, from 12450 Fair Lakes Circle, Suite 800, Fairfax, Virginia 22033 to 15036 Conference Center Drive, Suite 400, Chantilly, Virginia 20151;
- Change in Address of filal af GE Aviation System North America LLC (“GE Denmark”) from Frederiksborggade 15,3, Kobenhavn 1358, Denmark to Frederiksborggade 15,3, Kobenhavn 1360, Denmark;
- Change in Name of Blue Origin, LLC to Blue Origin Manufacturing, LLC due to corporate restructuring;
- Change in Name of Multiwerkplaats B.V. to MWP Works due to acquisition;
- Change in Name of General Dynamics Mission Systems – Italy S.r.l., General Dynamics Mission Systems Gulf LLC, and General Dynamics Mission Systems Asia-Pacific SDN BHD to Page Europa S.r.l., Page Middle East LLC, and Page Asia Pacific SDN BHD due to acquisition; and
- Change in Name of Jacobs Australia Pty Limited to Amentum Australia Proprietary Limited due to acquisition.
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DDTC Frequently Asked Questions (FAQ)
Q: What does it mean to be on one of DDTC’s lists of debarred parties?
A: Persons subject to statutory or administrative debarment are generally prohibited from participating directly or indirectly in ITAR-controlled activities, such as the export of technical data and other defense articles and the furnishing of defense services for which a license or other approval is required. Also, pursuant to ITAR § 127.1(d), it is a violation for a person with knowledge that another person is ineligible under ITAR § 120.16(c), which includes debarred parties, to, among other things, apply for, obtain, or use an export control document on behalf of a debarred party, or participate in a transaction subject to the ITAR that will benefit a debarred party, without first obtaining DDTC’s approval.
DDTC has specified the consequences of debarment in the ITAR, and the Federal Register Notices announcing the debarment provide further detail regarding the debarment. DDTC does not impose any restrictions on a debarred party’s eligibility to obtain banking services, engage in real estate transactions, purchase automobiles, or participate in any other activity not controlled under the ITAR.
Q: Why does the purchase documentation have to be issued within one year?
A: This requirement ensures the current validity of the export request. To comply with this requirement it is recommended all purchase documentation must be dated. A letter of explanation must be provided for any purchase documentation not meeting this requirement.
Q: How is a purchase order issued to a subsidiary handled in the license application?
A: The parent company who is the holder of the registration code must be identified in the applicant section of the license application. If the supporting documentation is issued to or identifies a subsidiary of the parent, the subsidiary’s information must be provided in the subsidiary section of the applicant block.
Q: Can I get an agreement in lieu of a brokering authorization?
A: No. In most cases, an agreement does not provide the full authorization for brokering activities. Parties must ensure broker registration and any required approval of brokering activities is obtained prior to brokering activities occurring.
Q: My company is entering into an agreement to grant a non-US person authorization to manufacture defense articles abroad. The agreement requires the transfer of ITAR-controlled technical data, defense articles, or the performance of defense services, but we are not transferring manufacturing know-how. Is an MLA still required?
A: Yes. ITAR § 120.57(d) provides that an MLA is an agreement “whereby a U.S. person grants a foreign person an authorization to manufacture defense articles abroad” and involves either (1) exports of defense articles, including technical data, or the performance of a defense service, or (2) the use by the foreign person of technical data or defense articles previously exported by the U.S. person. Thus, an MLA would be appropriate even if no manufacturing know-how is transferred. DDTC may authorize a manufacturing activity under a TAA when it meets all the conditions of ITAR § 124.13 and only limited defense services are furnished (e.g., quality control). Alternatively, if no defense services will be furnished and all the conditions of ITAR § 124.13 are met, an offshore procurement license may be appropriate.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To Ecuador
April 1, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Ecuador has requested to buy M4A1 rifles. The following non-MDE items will also be included: Magpul PMAG M4 magazines; technical manuals; training and support; and other related elements of logistics and program support. The estimated total cost is $64 million. The principal contractor will be determined after case implementation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
https://www.dsca.mil/press-media/major-arms-sales/ecuador-m4a1-rifles-and-support
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DSCA Notifies Congress of Potential FMS Sale To the Philippines
April 1, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the Philippines has requested to buy sixteen (16) F-16 C Block 70/72 aircraft; four (4) F-16 D Block 70/72 aircraft; twenty-four (24) F110-GE-129D or F100-PW-229 Engines (20 installed, 4 spares); twenty-two (22) Improved Programmable Display Generators (iPDG) (20 installed, 2 spares); twenty-two (22) AN/APG-83 Active Electronically Scanned Array (AESA) Scalable Agile Beam Radars (SABR) (20 installed, 2 spares); twenty-two (22) Modular Mission Computers 7000AH (or available mission computer) (20 installed, 2 spares); twenty-two (22) Embedded Global Positioning System (GPS) Inertial Navigation Systems (INS) (EGI) with Selective Availability Anti-Spoofing Module (SAASM) or M-Code capability and Precise Positioning Service (PPS) (20 installed, 2 spares); eighty-eight (88) LAU-129 guided missile launchers; twenty-two (22) M61A1 anti-aircraft guns (20 installed, 2 spares); twelve (12) AN/AAQ-33 Sniper Advanced Targeting Pods (ATP); twenty-four (24) Multifunctional Information Distribution System-Joint Tactical Radio Systems (MIDS-JTRS); one hundred twelve (112) Advanced Medium Range Air-to-Air Missiles (AMRAAMs) Air Intercept Missile (AIM)-120C-8 or equivalent missiles; four (4) AMRAAM guidance sections; thirty-six (36) Guided Bomb Unit (GBU)-39/B Small Diameter Bombs Increment 1 (SDB-1); two (2) GBU-39(T-1)/B SDB-1 Guided Test Vehicles; forty (40) AIM-9X Block II Sidewinder missiles; thirty-two (32) AIM-9X Block II Sidewinder Captive Air Training Missiles (CATMs); four (4) AIM-9X Block II Sidewinder guidance units; three (3) AIM-9X Block II Captive Air Training Missile (CATM) guidance units; sixty (60) MK-82 500-lb general purpose bombs; sixty (60) MK-84 2,000-lb general purpose bombs; thirty (30) Joint Direct Attack Munition (JDAM) KMU-572 tail kits for GBU-38 or Laser JDAM GBU-54; sixty (60) FMU-152 fuze systems; thirty (30) MAU-210 enhanced computer control groups (ECCG) for GBU-50 Enhanced Paveway II (EP II); and thirty-two (32) MXU-651 air foil groups (AFG) for GBU-50 EP II. The following non-MDE items will also be included: AN/ALQ-254 Viper Shield (VS) electronic warfare (EW) or equivalent systems; AMRAAM CATMs; AIM-9X Sidewinder training missiles and active optical target detectors (AOTD); Infrared Search and Track (IRST) systems; Air Combat Maneuvering Instrument (ACMI) range systems; FMU-139 Joint Programmable Fuzes (JPFs); missile containers; AN/ARC-238 radios; AN/APX-127 or equivalent Advanced Identification Friend or Foe (AIFF) Combined Interrogator Transponders (CIT) with Mode 5; KY-58 and KIV-78 cryptographic devices; AN/PYQ-10 Simple Key Loaders (SKLs); KGV-250X cryptographic devices; Scorpion Hybrid Optical-based Inertial Trackers (HObIT) or Joint Helmet Mounted Cueing Systems II (JHMCS II) helmet mounted displays; night vision devices (NVDs); spare image intensifier tubes; AN/ALE-47 Airborne Countermeasures Dispenser Systems (CMDS); AN/ALE-47 countermeasure processors; AN/ALE-47 sequencer switching units; AN/ALE-47 Control Display Units (CDUs); precision navigation; Joint Mission Planning Systems (JMPS); GPS Antenna System (GAS-1) antenna electronics; Sniper pod pylons; ADU-890 and
ADU-891 adapter units, LAU-117 and LAU-88 Maverick launchers, impulse cartridges, chaff, flares, ammunition, and other bomb components; BRU-57 bomb racks; BRU-61 munitions carriage assemblies; MAU-12 bomb racks and TER-9A triple ejection racks; Common Munitions Built-in-Test (BIT) Reprogramming Equipment (CMBRE); Rackmount Improved Avionics Intermediate Shop (RIAIS); Cartridge Actuated Devices/Propellant Actuated Devices (CAD/PAD); targeting systems; aircraft refurbishment after maintenance training; spare and repair parts, consumables and accessories; repair and return support; aircraft, engine, ground, and pilot life support equipment; classified and unclassified computer program identification number (CPIN) systems; pylons, launcher adapters, weapon interfaces, and bomb and ejection racks; fuel tanks; Precision Measurement Equipment Laboratory (PMEL) and calibration support; National Geospatial-Intelligence Agency (NGA) maps and mapping data; ferry and fuel support; classified and unclassified software and software support; classified and unclassified publications, manuals, and technical documentation; facilities and construction support; simulators and training devices; personnel training and training equipment; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $5.58 billion. The principal contractor will be Lockheed Martin, located in Greenville, SC. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
https://www.dsca.mil/press-media/major-arms-sales/philippines-f-16-aircraft
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DSCA Notifies Congress of Potential FMS Sale To the Kuwait
April 3, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Kuwait has requested to buy equipment and services required to upgrade and recertify PATRIOT PAC-2 Guidance Enhancement Missiles (GEM) and recertify PATRIOT Guidance Enhancement Missiles-Tactical (GEM-T). The following non-MDE items will be included: sustainment maintenance; special tools, support, and test equipment; repair parts; modification kits; common tools; shop equipment and fixtures; material handling equipment; test support; stockpile reliability testing and inspection; repair and return support; spare parts; training; replacement materials; support from field service representatives, technicians, mechanics, and other support personnel; and other related elements of logistics and program support. The estimated total cost is $400 million. The principal contractor will be RTX Corporation, located in Letterkenny, PA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Australia
April 9, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Australia has requested to buy up to two hundred (200) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM); and up to two hundred (200) AIM-120D-3 AMRAAMs. The following non-MDE items will be included: AMRAAM containers and support equipment; spare parts, consumables and accessories, repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.04 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Israel
April 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Israel has requested to buy additional Eitan 8V199TE21-D powerpack engines and engine components that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $85.5 million ($0 in MDE), included Eitan 8V199TE21-D powerpack engines and engine components; U.S. Government and contractor technical assistance; contractor non-recurring engineering; and other related elements of logistics and program support. This notification is for a combined notification of non-MDE Eitan 8V199TE21-D powerpack engines and engine components; U.S. Government and contractor technical assistance; contractor non-recurring engineering; and other related elements of logistics and program support. The estimated total cost is $180 million. The principal contractor will be Rolls-Royce Solutions America, Inc., located in Novi, MI. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To the Philippines
April 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Philippines has requested to buy the following defense articles and services: TH-73A training helicopters; aircraft simulator; spare engines; pack up kits; fuel tanks; aircraft hoists and lifts; commercial avionics; commercial flight management systems; commercial Global Positioning Systems; shipping containers; support and test equipment; consumables and accessories; integration and test support; repair and return support; spare and repair parts; unclassified software delivery and support; unclassified publications and technical documentation; personnel training and commercial training equipment; U.S. Government and contractor engineering, technical, logistics, and transportation support services, including in-country representative support; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $120 million. The principal contractor will be AgustaWestland Philadelphia Corporation (Leonardo), located in Philadelphia, PA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Morocco
April 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Kingdom of Morocco has requested to buy up to six hundred (600) FIM-92K Stinger Block I missiles. The following non-MDE items will also be included: U.S. Government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $825 million. The principal contractors will be RTX Corporation, located in Tucson, AZ; and Lockheed Martin, located in Syracuse, NY. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Ireland
April 23, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ireland has requested to buy thirty-six (36) Lightweight Command Launch Units (LwCLUs) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $8.7 million ($7.9 million in MDE), included forty-four (44) FGM-148 Javelin missiles. This notification is for a combined total of forty-four (44) FGM-148 Javelin missiles and thirty-six (36) Lightweight Command Launch Units (LwCLUs). The following non-MDE items will also be included: missile containers; U.S. Government technical assistance; Enhanced Producibility Basic Skills Trainers (EPBST); training; and other related elements of logistics and program support. The estimated total cost is $46 million. The prime contractors will be the Javelin Joint Venture between Lockheed Martin, located in Orlando, FL, and RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To The Netherlands
April 25, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Netherlands has requested to buy up to one hundred sixty-three (163) Tomahawk Block V All Up Rounds (AURs); twelve (12) Tomahawk Block IV AURs; up to ten (10) Tactical Tomahawk Weapons Control Systems (TTWCS); and up to two (2) Tomahawk Block IV telemetry missiles. The following non-MDE items will also be included: satellite data link terminals (KIV-18A); integrated secure broadcast systems (KSX-5); communications security devices (KGV-135A); technical, programmatic, engineering, and logistical support for the Tomahawk AUR missiles, TTWCS, and Mission Distribution Software; missile containers; software; hardware; training; training devices; unscheduled missile maintenance; spares; in-service support; communication equipment; operational flight test; publications; engineering and technical expertise to maintain the capability; non-recurring engineering; transportation; and other related elements of logistics and program support. The estimated total cost is $2.19 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. There are known offset requirements associated with this sale. See the attached annex for further details.
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DSCA Notifies Congress of Potential FMS Sale To Romania
April 28, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Romania has requested to buy one (1) AN/MPQ-65 Configuration 3+ Increment 3 radar set; one (1) AN/MSQ-132 Engagement Control Station; two (2) M903 launching stations; and one (1) Electrical Power Plant (EPP) III. The following non-MDE items will also be included: launching station modification kits; PATRIOT Advanced Capability-3 (PAC-3) Missile Segment Enhancement launcher conversion kit; generators; generator spare parts; prime movers; spare parts for prime movers; KG-250X encryptor; AN/TPX-57v1 identification friend or foe (IFF); KIV-77 encryptor; personnel communication equipment training; Defense Advanced Global Positioning Systems Receivers (DAGRs); U.S. Government and contractor representative technical assistance; engineering and logistics support services; publications and technical documentation; classified software; classified books and publications; and other related elements of logistics and program support. The estimated total cost is $280 million. The principal contractors will be RTX Corporation, located in Andover, MA, and Lockheed Martin, located in Bethesda, MD. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Poland
April 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy four hundred (400) AIM-120D3 Advanced Medium-Range Air-to-Air Missiles (AMRAAM); sixteen (16) AIM-120D3 AMRAAM guidance sections, including either Selective Availability Anti-Spoofing Modules or M-Code; and one (1) AIM-120 AMRAAM Instrumented Test Vehicle. The following non-MDE items will also be included: AMRAAM control sections, missile containers, and support equipment; Common Munitions Built-in-Test Reprogramming Equipment (CMBRE); ADU-891 adapter group test sets; KGV-135A encryption devices; Computer Program Identification Numbers (CPINs); spares and repair parts, consumables and accessories, and repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.33 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Kuwait
April 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Kuwait has requested to buy services, including delivery, installation, and upgrade, for PATRIOT Post-Deployment Build (PDB) 8.1. The following non-MDE items will be included: software development; delivery and support; sustainment maintenance; spare and repair parts; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; integration and test support; and other related elements of logistics and program support. The estimated total cost is $425 million. The principal contractor will be RTX Corporation, located in Waltham, MA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To India
April 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of India has requested to buy SeaVision software (including requested software enhancements); Technical Assistance Field Team (TAFT) training; remote software and analytic support; access to SeaVision documentation; and other related elements of logistics and program support. The estimated total cost is $131 million. The principal contractor will be Hawkeye 360, located in Herndon, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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Department of Commerce – Bureau of Industry and Security (BIS)
BIS Nominee Suggests 50% Rule for Entity List
April 11, 2025: Landon Heid, the President’s nominee to be assistant secretary of commerce for export administration, said April 10 that he wants the Bureau of Industry and Security to wage a “continuous battle every single day” to prevent China from obtaining restricted U.S. technology. He suggested that he wants to make subsidiaries automatically subject to Entity List restrictions, similar to OFAC’s 50% rule.
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Commerce Launches Section 232 Investigation on Imports of Medium-Duty and Heavy-Duty Trucks and their parts
April 23, 2025: The Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862) (“Section 232”), to determine the effects on the national security of the imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts.
The Bureau of Industry and Security (BIS) examined the current quantities and circumstances of these imports to determine if it threatens to impair U.S. national security and whether action is needed to address any such threat. Protection of U.S. national security and economic interests remains the President’s first priority, and this investigation will ensure American truck manufacturing remains protected.
Under Secretary of Commerce for Industry and Security Jeffrey Kessler released the following statement:
“A strong and resilient automotive and truck industry is vital to our national security. Under President Trump’s leadership, the Commerce Department will work to support this vital sector and carefully assess the risks posed by external threats and supply chain vulnerabilities.”
Interested parties are invited to submit written comments, data, analyses, or other information pertinent to the investigation to the Department of Commerce’s (Department) Bureau of Industry and Security (BIS), Office of Strategic Industries and Economic Security.
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Commerce Launches Section 232 Investigation on Imports of Processed Critical Minerals and Derivative Products
April 23, 2025: The Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862) (“Section 232”), to evaluate the effects of processed critical minerals and their derivative products on U.S. national security.
Critical minerals, including rare earth elements, are important production inputs required for both civilian and defense-related applications. However, China currently dominates the global market for processing critical minerals and is the leading producer of 30 out of 44 critical minerals. In addition, China is expanding its influence by acquiring mining concessions and operations around the world.
Through this Section 232 investigation, the Bureau of Industry and Security (BIS) is evaluating the foreign sources of processed critical minerals and their derivative products and assessing the associated risks. BIS is also analyzing current and potential U.S. capabilities to process critical minerals and their derivative products. This is an important step in securing America’s mineral future and prioritizing national security.
U.S. Under Secretary of Commerce for Industry and Security Jeffrey Kessler released the following statement:
“The United States should not allow foreign adversaries to have a chokehold on critical inputs for our economy and defense industrial base. Under President Trump’s leadership, the Commerce Department will carefully assess the risks posed by external threats and supply chain vulnerabilities.”
Interested parties are invited to submit written comments, data, analyses, or other information pertinent to the investigation to BIS’s Office of Strategic Industries and Economic Security.
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U.S. Census Bureau
Update to the Automated Export System Trade Interface Requirements – Appendix U – HTS/Schedule B Classifications Requiring Used Vehicle Reporting
April 7, 2025:
CSMS # 64646715 – Update to the Automated Export System Trade Interface Requirements – Appendix U – HTS/Schedule B Classifications Requiring Used Vehicle Reporting.
Update to the Automated Export System Trade Interface Requirements (AESTIR) – Appendix U – HTS/Schedule B Classifications Requiring Used Vehicle Reporting has been posted to CBP.gov.
The following HTS/Schedule B code numbers have been added: 8432.80.0010.
The following HTS/Schedule B code numbers have been removed: 8708.30.0050.
Documentation is available under the ACE AESTIR, Appendix U in the AES webpage which can be located at: https://www.cbp.gov/document/guidance/appendix-u-htsschedule-b-classifications-requiring-used-vehicle-reporting.
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How to Resolve Common AES Response Messages
April 21, 2025:
When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning. It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations.
To help you take the appropriate action, here is guidance on how to address one of the most frequent Response Messages that were generated in the AES for the previous month.
Response Code: 649
Narrative: Quantity 1 Cannot Exceed Shipping Weight
Severity: Fatal
Reason: The Unit of Measure 1 for the reported Schedule B/HTS requires kilograms and Quantity 1 exceeds the Shipping Weight.
Resolution: For the Schedule B/HTS reported, Quantity 1 must be reported in kilograms. Quantity 1 in kilograms cannot exceed the Shipping Weight.
Verify the Quantity 1 and Shipping Weight, correct the shipment and resubmit.
For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.
As a reminder, filers have multiple resources that they can use when filing EEI to the AES.
| 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
Department of Commerce – Bureau of Industry and Security (BIS)
April 2, 2025: A seven-count indictment was unsealed in federal court in Brooklyn charging José Adolfo Macías Villamar, also known as “Fito,” with international cocaine distribution conspiracy; international cocaine distribution; using firearms in furtherance of drug trafficking; smuggling firearms from the United States; and straw purchasing of firearms conspiracy. Since at least 2020, he has been the leader of Los Choneros, one of Ecuador’s most violent drug trafficking and transnational criminal organizations. The defendant is not in U.S. custody.
https://www.bis.gov/news-updates
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April 2, 2025: An indictment was unsealed charging Mohammad Jawaid Aziz, also known as Jawaid Aziz Siddiqui and Jay Siddiqui, 67, of Pakistan and Canada, with conspiracy to violate U.S. export laws and violating U.S. export laws. Siddiqui was arrested on March 21 in the Western District of Washington while attempting to cross into the United States from Canada. He remains detained, pending transfer to the District of Minnesota.
https://www.bis.gov/news-updates
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April 2, 2025: Oleg Sergeyevhich Patsulya, a Russian national, was sentenced to 70 months, or nearly six years, in prison for his role in a conspiracy to export controlled aviation technology to Russia and to launder money in connection with the illegal export scheme. In December 2024, Patsulya’s co-conspirator, Russian national Vasilii Sergeyevich Besedin, was sentenced to two years in prison for his role in the scheme.
https://www.justice.gov/opa/pr/leader-export-control-evasion-scheme-sentenced-70-months-prison
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April 4, 2025: 90 Fed. Reg. 14783: Pursuant to section 766.24 of the Export Administration Regulations, 15 CFR parts 730-774, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, through its Office of Export Enforcement (“OEE”), has requested the issuance of an Order temporarily denying, for a period of 180 days, the export privileges under the Regulations of: ExHigh Air Space Ltd. (“ExHigh”), Geoffrey Chune Omariba (“Chune”), and Nader Ali Saboori Haghighi (“Haghighi”), (collectively, the “Respondents”). OEE’s request and related information indicate that these parties are located in Nairobi, Kenya, and Belgrade, Serbia, at the respective addresses listed on the caption page of this order. OEE’s request and related information further indicates that the Respondents have obtained, and continue to engage in attempts to obtain, controlled aircraft parts from the United States in order to divert those items to Russia contrary to the requirements of the Regulations.
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April 30, 2025: The Justice Department announced that it has declined the prosecution of Universities Space Research Association (USRA) after it self-disclosed to the Department’s National Security Division (NSD) criminal violations of U.S. export control laws committed by its former employee, Jonathan Soong. Soong pleaded guilty to willfully violating the Export Administration Regulations (EAR) by exporting U.S. Army-developed aviation software to a university in the People’s Republic of China (PRC) that had been placed on the Commerce Department’s Entity List and was sentenced to 20 months in prison.
Sanctions
Department of Commerce, Bureau of Industry and Security (BIS)
April 3, 2025: the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated list of foreign companies that have made boycott-related requests, including requests to comply with the Arab League boycott of Israel. BIS added 30 parties, in addition to removing 18 entities who certified that they have stopped making boycott-related requests in transactions with U.S. persons. BIS maintains anti-boycott regulations that discourage and, in certain circumstances, prohibit U.S. persons or businesses from participating in unsanctioned foreign boycotts, focusing on the Arab League boycott of Israel.
Parties Added to the Requester List:
| REQUESTER | LOCATION |
| ATEL TEKNOLOJI VE SAVUNMA SANAYI | TURKEY |
| B.M. NAGANO INDUSTRIES | MALAYSIA |
| BASHUNDHARA READYMIX AND CONSTRUCTION INDUSTRIES LTD | BANGLADESH |
| BENCHMARK ELECTRONICS (M) SDN BHD | MALAYSIA |
| BRITISH AMERICAN TOBACCO BANGLADESH COMPANY LTD | BANGLADESH |
| DHL Global Forwarding Qatar W.L.L. | QATAR |
| EOLANE MALAYSIA SDN BHD | MALAYSIA |
| INTEC DISTRIBUTIONS LTD., | BANGLADESH |
| INTERSCIENCE TECHNOLOGIES | BANGLADESH |
| ITG ELECTRONICS | MALAYSIA |
| J.K. SPINNING MILLS LTD | BANGLADESH |
| KUEHNE-NAGEL | TURKEY |
| KUWAIT INVESTMENT AUTHORITY | KUWAIT |
| KUWAIT PETROLEUM COMPANY | KUWAIT |
| LEADER SPORT LLC | UNITED ARAB EMIRATES |
| LOTTE CHEMICAL PAKISTAN LIMITED | PAKISTAN |
| MASHREQ BANK KUWAIT BRANCH | KUWAIT |
| MOH / THE STATE COMP. FOR MARKETING DRUGS MEDICAL APPLIANCES | IRAQ |
| NATIONAL HEART FOUNDATION OF BANGLADESH | BANGLADESH |
| PENTAMASTER EQUIPMENT MFG | MALAYSIA |
| PETROCHEMICAL INDUSTRIES COMPANY (K.S.C.) | KUWAIT |
| PETROFAC INTERNATIONAL (UAE) LLC | ALGERIA |
| SANMINA-SCI SYSTEMS | MALAYSIA |
| SAUDIA TECHNIC | SAUDI ARABIA |
| SMART INDUSTRIES | MALAYSIA |
| SPECIALIZED SECURITY SYSTEMS CO. WII | KUWAIT |
| SPM OIL AND GAS | PAKISTAN |
| STANDARD CHARTERED BANK | PAKISTAN |
| UNITED BANK LIMITED | PAKISTAN |
| WATER & ENVIRONMENTAL TECHNOLOGY COMPANY, LLC | SAUDI ARABIA |
https://www.bis.gov/press-release/bis-updates-boycott-requester-list-8 and
https://www.bis.gov/press-release/bis-updates-boycott-requester-list-8
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April 25, 2025: 90. Fed. Reg. 17339; The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL). Of the 18 persons being added: five are under the destination of China, People’s Republic of (China); six are under the destination of Finland; three are under the destination of Türkiye; two are under the destination of Kazakhstan; one is under the destination of Italy; and one is under the destination of the United Kingdom. BIS is also amending the EAR by removing five persons from the UVL. Of the five persons being removed, three are under the destination of China and two are under the destination of the United Arab Emirates.
Pursuant to § 744.15(c) of the EAR, this rule adds 18 persons to the UVL by amending supplement no. 6 to part 744 of the EAR to include their names and addresses. This final rule implements the decision to add the following 18 persons located in the following destinations to the UVL:
- Arctic Star Co., Ltd.; Henixio Aviation Co., Ltd.; Shusum Construction Ltd.; Sino-World International Co., Ltd.; and Vauxhall International Co., Ltd., under the destination of China;
- Buran TMI; Finland Multi Center FMC OY; Finnalliance OY; Inmargo OY; Karjalan Puutyo; and MM Cargo OY, under the destination of Finland;
- Euro Servizi Elettromeccanici Industriali SEI., under the destination of Italy;
- EltexAlatau and Inter-Traid Electro, under the destination of Kazakhstan;
- Bagil Havacilik, Basak Traktor, and Ozkanlar Grup Makine AS, under the destination of Türkiye; and
- Identiparts Ltd., under the destination of the United Kingdom.
https://www.federalregister.gov/documents/2025/04/25/2025-07185/revisions-to-the-unverified-list
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
April 1, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the U.S. Department of Justice, targeted a network of six entities and two individuals based in Iran, the United Arab Emirates (UAE), and the People’s Republic of China (PRC) responsible for the procurement of unmanned aerial vehicle (UAV) components on behalf of Iran-based Qods Aviation Industries (QAI)—a leading manufacturer for Iran’s UAV program. This network has also facilitated procurement for other entities in Iran’s military-industrial complex, to include Iran Aircraft Manufacturing Industrial Company (HESA) and Shahid Bakeri Industrial Group (SBIG). This action marks the second round of sanctions targeting Iranian weapons proliferators since the President issued National Security Presidential Memorandum 2 on February 4, 2025, ordering a campaign of maximum pressure on Iran.
The following individuals have been added to OFAC’s SDN List:
- Akbari, Hossein of Iran; and
- Yousefnejad, Abbas of Iran.
The following entities have been added to OFAC’s SDN List:
- Diamond Castle Elctronics Trading LLC of the United Arab Emirates;
- Future Trends Goods Wholesalers LLC of the United Arab Emirates;
- Infracom Communications Network FZE of the United Arab Emirates;
- Phenomena International General Trading LLC of the United Arab Emirates;
- Rah Roshd International Trade Exchanges Development of Iran; and
- Zibo Shenbo Machinelectronics Co LTD of China.
https://ofac.treasury.gov/recent-actions/20250401 and
https://home.treasury.gov/news/press-releases/sb0066
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April 2, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against a network of Houthi financial facilitators and procurement operatives working in coordination with Sa’id al-Jamal, a senior Houthi financial official backed by Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). This network has procured tens of millions of dollars’ worth of commodities from Russia, including weapons and sensitive goods, as well as stolen Ukrainian grain, for onward shipment to Houthi-controlled Yemen. Additionally, OFAC has identified eight digital asset wallets used by the Houthis to transfer funds associated with their activities.
The following individuals have been added to OFAC’s SDN List:
- Beliyakov, Yuri Vladimirovich of Russia;
- Ghairat, Hushang of Afghanistan;
- Ghairat, Sohrab of Afghanistan;
- Jafari, Hassan of Iran; and
- Vidanov, Vyacheslov Vladimirovich of Russia.
The following entities have been added to OFAC’s SDN List:
- AM ASIA M6 LTD of China;
- LLC Edison of Russia;
- LLC Kolibri Group Russia; and
- LLC Sky Frame of Russia.
The following vessel has been added to OFAC’s SDN List:
- AM Theseus (UBKZ6) Bulk Carrier Russia flag; MMSI 273254900 (vessel).
https://ofac.treasury.gov/recent-actions/20250402
https://home.treasury.gov/news/press-releases/sb0068
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April 2, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has released Quarterly Reports of Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by OFAC under Section 906(a)(1) of the TSRA from October through December 2024. Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran under the specific licensing regime set forth in Section 906 of the TSRA.
https://ofac.treasury.gov/media/934191/download?inline
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April 7, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued Russia-related General License 13M, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.”
Additionally, OFAC has updated two Frequently Asked Questions (FAQ 999, FAQ 1118).
GENERAL LICENSE NO. 13M: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”
- S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, July 9, 2025.
FAQ 999:
Q: What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?
A: OFAC issued Russia-related General Licenses (GLs) 8L and 115A to authorize the wind-down of certain energy-related transactions and civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive (see FAQs 976 and 977).
OFAC issued GL 13M to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13M, see FAQ 1118.
OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.
Note that GL 8L, GL 13M, GL 14, and GL 115A continue to authorize against the Russia-related Sovereign Transactions Directive.
FAQ 1118:
Q: As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13M authorize transactions that involve the payment of this exit tax?
A: The Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, “Directive 4 entities”). As noted in FAQ 1002, this includes both direct and indirect transactions.
OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called “exit taxes” imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.
GL 13M authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13M.
Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an “exit tax” should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC’s Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.
While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.
https://ofac.treasury.gov/faqs/1118 and
https://ofac.treasury.gov/recent-actions/20250407
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April 9, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated five entities, and one individual based in Iran for their support to key entities that manage and oversee Iran’s nuclear program, including the Atomic Energy Organization of Iran (AEOI) and the AEOI-subordinate Iran Centrifuge Technology Company (TESA). This action, which targets entities procuring, or manufacturing, critical technologies for TESA and AEOI, is taken in furtherance of U.S. policy that Iran be denied a nuclear weapon, as stated in National Security Presidential Memorandum 2.
The following individual has been added to OFAC’s SDN List:
- Mosallat, Majid of Iran.
The following entities have been added to OFAC’s SDN List:
- Atbin Ista Technical And Engineering Company of Iran;
- Azarab Industries Co. of Iran;
- Pars Reactors Construction and Development Company of Iran;
- Pegah Aluminum Arak Company of Iran; and
- Thorium Power Company of Iran.
https://ofac.treasury.gov/recent-actions/20250409
https://ofac.treasury.gov/recent-actions
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April 9, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Mexican national Jesus Alfredo Beltran Guzman, a key leader of the Beltran Leyva Organization (BLO), for playing a significant role in the trafficking of illicit drugs, including fentanyl, cocaine, heroin, and methamphetamine, into the United States. One of the most powerful drug trafficking organizations in the world, the BLO is heavily involved in the transportation and distribution of deadly drugs, including fentanyl, to the United States, and has been one of the largest suppliers of cocaine to the U.S. market for over two decades. OFAC carried out this investigation in coordination with the Federal Bureau of Investigation (FBI) and Drug Enforcement Administration (DEA).
The following individual has been added to OFAC’s SDN List:
- Beltran Guzman of Mexico.
https://ofac.treasury.gov/recent-actions/20250409
https://home.treasury.gov/news/press-releases/sb0076
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April 10, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated United Arab Emirates (UAE)-based Indian national Jugwinder Singh Brar (Brar), who owns multiple shipping companies that boast a fleet of nearly 30 vessels, many of which operate as part of Iran’s “shadow fleet.” OFAC also designated two UAE- and two India-based entities that own and operate Brar’s vessels that have transported Iranian oil on behalf of the National Iranian Oil Company (NIOC) and the Iranian military. Brar’s vessels engage in high-risk ship-to-ship (STS) transfers of Iranian petroleum in waters off Iraq, Iran, the UAE, and the Gulf of Oman. These cargoes then reach other facilitators who blend the oil or fuel with products from other countries and falsify shipping documents to conceal links to Iran, allowing these cargoes to reach the international market.
The following individual has been added to OFAC’s SND List:
- Brar, Jugwinder Singh of the United Arab Emirates.
The following entities have been added to OFAC’s SDN List:
- B And P Solutions Private Limited of India;
- Global Tankers Private Limited of India;
- Glory International FZ-LLC of the United Arab Emirates;
- Guangsha Zhoushan Energy Group Co., Ltd of China;
- Marziya Shipping OPC Pvt Ltd of India;
- Prime Tankers LLC of the United Arab Emirates;
- Rising Phoenix Provider NV of Suriname; and
- Valiant Marine Ventures FZE of the United Arab Emirates.
The following vessels have been added to OFAC’s SDN List:
- Amor (TJMC800) Crude Oil Tanker Cameroon flag; MMSI 613884000 (vessel);
- Chil 1(C5J280) Chemical/Oil Tanker Gambia flag; MMSI 629009268 (vessel);
- Global Ace (3FJW3) Chemical/Oil Tanker Panama flag; MMSI 374808000 (vessel);
- Global Angel (3FVC9) Oil Products Tanker Panama flag; MMSI 353283000 (vessel);
- Global Asphalt (3FZQ3) Oil Products Tanker Panama flag; MMSI 354816424 (vessel);
- Global Beauty (3E6819) Chemical/Products Tanker Panama flag; MMSI 352004530 (vessel);
- Global Crest (3FHI8) Crude Oil Tanker Panama flag; MMSI 372463000 (vessel);
- Global Dignity (3E2062) Chemical/Products Tanker Panama flag; MMSI 352898795 (vessel);
- Global Dominance (V2YZ5) Bunkering Tanker Antigua & Barbuda flag; MMSI 305290000 (vessel);
- Global Eagle (D6A3537) Chemical/Products Tanker Comoros flag; MMSI 620999538 (vessel);
- Global Elegance (E5U4389) Chemical/Oil Tanker; Former Vessel Flag Cook Islands; MMSI 518998409 (vessel);
- Global Emerald (3E2462) Products Tanker Panama flag; MMSI 352001105 (vessel);
- Global Everest (3EUO4) Oil Products Tanker Panama flag; MMSI 352995000 (vessel);
- Global Falcon (T8A4956) Chemical/Oil Tanker Palau flag; MMSI 511101536 (vessel);
- Global Genesis (E5U3771) Oil Products Tanker; Former Vessel Flag Cook Islands; MMSI 518100860 (vessel);
- Global Hawk (E5U3877) Chemical/Oil Tanker; Former Vessel Flag Cook Islands; MMSI 518100966 (vessel);
- Global Maharani (8P2426) Oil Products Tanker Barbados flag; MMSI 314932000 (vessel);
- Global Peace (E5U3881) Oil Products Tanker Cook Islands flag; MMSI 518100969 (vessel);
- Global Peak (3FBM7) Products Tanker Panama flag; MMSI 354117000 (vessel);
- Global Rani (T8A4955) Chemical/Oil Tanker Palau flag; MMSI 511101535 (vessel);
- Global Star (3FYM8) Chemical/Oil Tanker Panama flag; MMSI 354068000 (vessel);
- Global Star I (3E4656) Oil Products Tanker Panama flag; MMSI 352002878 (vessel);
- Harmony (8PVO9) Oil Products Tanker Barbados flag; MMSI 314825000 (vessel);
- Luanda 1(3FWF5) Anchor Handling Vessel Panama flag; MMSI 357029000 (vessel);
- Mirage (8P2465) Chemical/Oil Tanker Barbados flag; MMSI 314963000 (vessel);
- Nadiya (3E3423) Oil Products Tanker Panama flag; MMSI 352001151 (vessel);
- Ocean Princess 1 (3EVR9) Oil Products Tanker Panama flag; MMSI 373094000 (vessel);
- Purna (C5J300) Oil Products Tanker Gambia flag; MMSI 629000928 (vessel);
- Simran (HO4539) Oil Products Tanker Panama flag; MMSI 356762000 (vessel); and
- Virgo (C5J448) Crude Oil Tanker Gambia flag; MMSI 629009436 (vessel).
https://ofac.treasury.gov/recent-actions/20250410
https://home.treasury.gov/news/press-releases/sb0082
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April 15, 2025: The Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four individuals affiliated with La Nueva Familia Michoacana (LNFM), a Mexican cartel designated as a Foreign Terrorist Organization and a Specially Designated Global Terrorist, that has poisoned Americans by trafficking fentanyl and other illicit drugs into the United States. LNFM’s crimes also include the smuggling of illegal aliens into the United States and violence against its rivals and Mexican security forces, utilizing drones and bombs in addition to conventional firearms. Those sanctioned, all of whom are siblings, include the group’s notorious co-leaders: Johnny Hurtado Olascoaga and Jose Alfredo Hurtado Olascoaga.
The following individuals have been added to OFAC’s SDN List:
- Hurtado Olascoga, Adita of Mexico; and
- Hurtado Olascoga, Ubaldo of Mexico.
https://ofac.treasury.gov/recent-actions/20250415 and
https://ofac.treasury.gov/media/934231/download?inline=
https://home.treasury.gov/news/press-releases/sb0087
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April 16, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a China-based independent “teapot” refinery Shandong Shengxing Chemical Co., Ltd. for its role in purchasing more than a billion dollars’ worth of Iranian crude oil, including from a front company for Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). OFAC also imposed additional sanctions on several companies and vessels responsible for facilitating Iranian oil shipments to China as part of Iran’s “shadow fleet.”
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued an Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion.
The following entities have been added to OFAC’s SDN List:
- Bestla Company Limited of the Marshall Islands;
- Civic Capital Shipping Inc. of Panama;
- Dexiang Shipping Co., Limited of China;
- Oceanic Orbit Incorporated of Panama;
- Pro Mission SDN BHD of Malaysia;
- Shadong Shengxing Chemical Co., Ltd. of China; and
- Starboard Shipping Inc. of Panama City.
The following vessels have been added to OFAC’s SDN List:
- Bestla (3E6593) Crude Oil Tanker Panama flag; MMSI 352003044 (vessel);
- Egret (3E2524) Crude Oil Tanker Panama flag; MMSI 352001512 (vessel);
- Nyantara (3E2243) Crude Oil Tanker Panama flag; MMSI 352002259 (vessel);
- Rani (3EED4) Crude Oil Tanker Panama flag; MMSI 354907000 (vessel); and
- Reston (TJ4HG) Crude Oil Tanker Cameroon flag; MMSI 613464706 (vessel).
https://ofac.treasury.gov/recent-actions/20250416
https://home.treasury.gov/news/press-releases/sb0090
https://ofac.treasury.gov/media/934236/download?inline
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April 17, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Yemen-based International Bank of Yemen Y.S.C. (IBY) for its financial support to Ansarallah, commonly known as the Houthis, which is part of the Iran threat network. As part of this designation, OFAC sanctioned key leaders or officials of IBY, Kamal Hussain Al Jebry, Ahmed Thabit Noman Al-Absi, and Abdulkader Ali Bazara. The designation of IBY complements the whole-of-government effort to stop Iran-backed Houthi attacks against commercial shipping in the Red Sea.
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued Counter Terrorism General License 33, “Authorizing the Wind Down of Transactions Involving International Bank of Yemen (IBY).”
GENERAL LICENSE NO. 33: “Authorizing the Wind Down of Transactions Involving International Bank of Yemen (IBY)”
(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), that are ordinarily incident and necessary to the wind down of any transaction involving International Bank of Yemen (IBY), or any entity in which IBY owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, May 17, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the GTSR.
The following individuals have been added to OFAC’s SDN List:
- Al Jerby, Kamal Hussein of Yemen;
- Al-Absi, Ahmed Thabit Noman of Yemen; and
- Bazra, Abdulkader, Ali of Yemen.
The following entity has been added to OFAC’s SDN List:
- International Bank of Yemen Y.S.C. of Yemen.
https://ofac.treasury.gov/recent-actions/20250417 and
https://ofac.treasury.gov/recent-actions/20250416
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April 22, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Iranian national and liquified petroleum gas (LPG) magnate Seyed Asadoollah Emamjomeh and his corporate network, which is collectively responsible for shipping hundreds of millions of dollars’ worth of Iranian LPG and crude oil to foreign markets. Emamjomeh’s expansive network includes a vessel, the TINOS I, which intended but failed to load cargo in 2024 off the coast of Houston, Texas. In addition to crude oil, LPG continues to be a major source of revenue for the Iranian regime, the proceeds of which fund Iran’s nuclear and advanced conventional weapons programs, as well as regional proxy groups and partners such as Hizballah, the Houthis, and Hamas.
The following individuals have been added to OFAC’s SDN List:
- Emamjomeh, Meisam of the United Arab Emirates; and
- Emamjomeh, Seyed Asadoollah of the United Arab Emirates.
The following entities have been added to OFAC’s SDN List:
- Arsa Gas Company of Iran;
- Caspian Petrochemical Fze of the United Arab Emirates;
- Nilgon Parsa Caspian Shipping Company of Iran;
- Parsa Fidar Paydar Engineering and Technology Company of Iran;
- Parsa Salakh Qeshm Idustrial Complex of Iran;
- Parsa Trabar Caspian International Transportation Company of Iran;
- Parsa Trabar Persia International Transportation Company of Iran;
- Pasar Gas Company of Iran;
- Pasar Gas Novin Trading Company of Iran;
- Pearl Petrochemical Fze of the United Arab Emirates;
- Petro Parsa Caspian Iranian Company of Iran; and
- Worldwide LPG Limited of the United Kingdom.
The following vessel has been added to OFAC’s SDN List:
- Tinos I (3E5261) LPG Tanker Panama flag; MMSI 352003638 (vessel).
https://ofac.treasury.gov/recent-actions/20250422
https://home.treasury.gov/news/press-releases/sb0093
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April 28, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted three vessels and their owners for providing support to Ansarallah, commonly known as the Houthis, which is part of the Iranian regime’s network of terrorist proxies and partners. The group has deployed missiles, unmanned aerial vehicles, and naval mines to attack commercial shipping interests in the Red Sea, threatening global freedom of navigation and the integrity of international commerce. The Houthis also profit significantly from the shipment of goods through ports they control, profiting, in particular, from the discharge of refined petroleum products.
The following entities have been added to OFAC’s SDN List:
- Bagsak Shipping Inc of Mauritius;
- Great Success Shipping Co of Lebanon; and
- Zaas Shipping & Trading Co of Lebanon.
The following vessels have been added to OFAC’s SDN List:
- Maisan (3E4995) Products Tanker Panama flag; MMSI 352002675 (vessel);
- Tulip Bz (T7AV5) LPG Tanker San Marino flag; MMSI 268249300 (vessel); and
- White Whale (H9HR) Crude/Oil Products Tanker Panama flag; MMSI 374932000 (vessel).
https://ofac.treasury.gov/recent-actions/20250428
https://home.treasury.gov/news/press-releases/sb0113
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April 29, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six entities and six individuals based in Iran and the People’s Republic of China (PRC) for their role in a network procuring ballistic missile propellant ingredients on behalf of Iran’s Islamic Revolutionary Guard Corps (IRGC). This network has facilitated the procurement of sodium perchlorate and dioctyl sebacate from the PRC to Iran. Sodium perchlorate is used to produce ammonium perchlorate, which is controlled by the Missile Technology Control Regime (MTCR), a multilateral political understanding among states that seek to limit the proliferation of missiles and missile technology. Both ammonium perchlorate and dioctyl sebacate are chemicals usable in solid propellant rocket motors, which are commonly used for ballistic missiles.
The following individuals have been added to OFAC’s SDN List:
- Asgari, Mohammed of Iran;
- Modarres Fathi, Forough of Iran;
- Pour Kazemi, Abbas of Iran;
- Zargar Bab Aldashti, Abed of Iran;
- Zagar Bab Aldashti, Hamed of Iran; and
- Zagar Bab Aldashti, Zahra of Iran.
The following entities have been added to OFAC’s SDN List:
- China Chlorate Tech Co Limited of China;
- Dongying Weiaien Chemical Co Ltd of China;
- Saman Tejarat Barman Trading Company of Iran;
- Shenzhen Amor Logistics Co Ltd of China;
- Yanling Chuanxing Chemical Plant General Partnership of China; and
- Yanling Lingfeng Chlorate Co Ltd of China.