This newsletter is a listing of the latest changes in export control regulations through August 31, 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.
REGULATORY UPDATES
Department of State, Directorate of Defense Trade Controls (DDTC)
Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses
August 8, 2025: 90. Fed. Reg. 33462: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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International Traffic in Arms Regulations: U.S. Munitions List Targeted Revisions
August 27, 2025: 90 Fed. Reg. 41778: The Department of State published a final rule in the Federal Register to amend §§ 121.0, 121.1, and 126.9 of the International Traffic in Arms Regulations (ITAR) making revisions to the U.S. Munitions List (USML), adding and updating definitions, and creating a new license exemption.
This rule is one in a series of rules that streamlines defense trade and facilitates cooperation with U.S. allies and partners while reducing the regulatory burden for exporters, in support of the President’s April 9, 2025, Executive Order (E.O.) 14268, “Reforming Foreign Defense Sales to Improve Speed and Accountability,” which directs the Departments of State and Defense to review the USML to focus its protections.
This final rule expands on the interim final rule published January 17, 2025 (the IFR), and makes other changes based on DDTC’s ongoing assessments and periodic review of the USML. The revisions and the new exemption will take effect on September 15, 2025.
The rule includes revisions designed to promote the competitiveness of the U.S. defense industrial base, while continuing to protect the warfighter’s edge. With this rule, DDTC also takes steps to reduce unnecessary regulatory burden and act consistently with the President’s order to focus the USML on the most sensitive technologies.
This rule removes the following items from the USML, as the Department has determined they no longer provide a critical military or intelligence advantage:
- Certain Global Navigation Satellite Systems (GNSS) anti-spoofing and GNSS anti-jam systems
- Certain Controlled Reception Pattern Antennas (CRPAs) for Position, Navigating, and Timing (PNT) purposes
- Airborne Collision Avoidance System (ACAS) antennas
- Tungsten- and steel-based lead-free birdshot projectiles
Items removed from the USML will become subject to Commerce’s Export Administration Regulations (EAR).
In response to public comments identifying commercial applications of some extra-large autonomous underwater uncrewed vessels (UUVs) that will be described in USML Category XX(a)(10), this final rule adds a new exemption from ITAR licensing requirements to facilitate U.S. participation and collaboration in certain tasks that use these UUVs, specifically: scientific research, natural resource exploration, certain commercial or civil infrastructure operations (e.g., oil and gas pipeline inspections, telecommunication cable repairs), or search and rescue operations.
This rule also includes revisions that improve the clarity and usability of the regulations, and the preamble to the rule provides clarifications in response to public comments on the IFR. Finally, this rule makes permanent the existing temporary controls on items specially designed for the F-47 Next Generation Air Dominance Platform.
Although it is not seeking public comment in this final rule, the Department of State welcomes submissions from members of the public identifying specific descriptions of items that, in their view, the Department of State should consider revising, removing, or adding to the USML in future rulemaking. Members of the public are often uniquely positioned to provide information that can assist the Department of State in its review of the USML, including technology developments, commercial use of defense technology, and industry interpretation and application of particular terminology.
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60-Day Notice of Proposed Information Collection: Statement of Political Contributions, Fees, and Commissions Relating to Sales of Defense Articles and Defense Services
August 28, 2025: 90. Fed. Reg. 41866: The Department of State is seeking Office of Management and Budget (OMB) approval for the information identified in the title. 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/ddtc_public?id=ddtc_public_portal_news_and_events
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60-Day Notice of Proposed Information Collection: Nontransfer and Use Certificate
August 28, 2025: 90 Fed. Reg. 41471: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described in the title. 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/ddtc_public?id=ddtc_public_portal_news_and_events
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DDTC Name And Address Changes Posted To Website
August 12 through 13, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Name change of ATLAS ELEKTRONIK GmbH to TKMS ATLAS ELEKTRONIK GmbH due to acquisition;
- Name change of GF Machining Solution AG to United Machining Mill AG due to acquisition;
- Name and address change of NVL B.V. Co. ZKG, Zum Alten Speicher 11 28759 Bremen, Germany to Civmec Limited (CVL), 16 Nautical Drive, Henderson, WA due to change in ownership; and
- Name and address change of Luerssen Australia Pty Ltd. (Luerssen), 16 Nautical Drive, Henderson, WA 6166 to Civmec Defence Industries (CDI), 16 Nautical Drive, Henderson, WA 6166 due to ownership change.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To Ukraine
August 5, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment; repair services; and long-term sustainment support for M777 howitzers. The following non-MDE items will be included: technical assistance; training; publications; and other related elements of logistics and program support. The estimated total cost is $104 million. The principal contractor will be BAE Systems, located in Barrow-in-Furness, England. 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 Ukraine
August 5, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy transportation and consolidation services in support of security assistance programs and other related elements of logistics and program support. The estimated total cost is $99.5 million. The principal contractor(s) will be determined from approved vendors. 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
August 6, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Australia has requested to buy equipment and services to support maintenance of its MC-55A aircraft fleet, to include major and minor modifications; spare parts; consumables and accessories; repair and return support; 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 $404 million. The principal contractor will be L3 Harris, located in Greenville, TX. 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 Canada
August 8, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Canada has requested to buy a fleet of up to sixty (60) Joint Light Tactical Vehicles (JLTVs); and up to nine (9) JLTV cargo trailers. The following non-MDE items will also be included: communication equipment; mobility equipment; lethality and survivability enhancements; spare and repair parts; special tools and test equipment (STTE); technical manuals and publications; maintenance trainers; new equipment training; total package fielding support; depot level maintenance/repair and return support; U.S. Government and contractor technical, engineering, and logistics personnel services; and other related elements of logistics and program support. The estimated total program cost is $160 million. The principal contractors will be AM General, LLC, located in Auburn Hills, MI and Mishawaka, IN. The purchaser typically requests offsets. 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 Nigeria
August 13, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Nigeria has requested to buy one thousand two (1,002) MK-82 general purpose 500 lbs bombs; one thousand two (1,002) MXU-650 Air Foil Groups (AFGs) for 500 lb Paveway II GBU-12; five hundred fifteen (515) MXU-1006 AFGs for 250 lbs Paveway II GBU-58; one thousand five hundred seventeen (1,517) MAU-169 or MAU-209 computer control group (CCG) for Paveway II GBU-12/GBU-58; one thousand two (1,002) FMU-152 joint programmable fuzes; and five thousand (5,000) Advanced Precision Kill Weapon System II (APKWS II) all-up-rounds (AURs) (consisting of one each WGU-59/B guidance section (GS); high-explosive warhead; and MK66-4 rocket motor). The following non-MDE items will also be included: FMU-139 joint programmable fuzes; bomb components, impulse cartridges, and high-explosive and practice rockets; integration support and test equipment; U.S. Government and contractor technical, engineering, and logistics personnel services; and other related elements of logistical and program support. The total estimated program cost is $346 million. The principal contractors will be RTX Missiles and Defense, Tucson, AZ; Lockheed Martin Corporation, Archibald, PA; and BAE Systems, Hudson, NH. 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 Bahrain
August 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Bahrain has requested to buy four (4) M142 High Mobility Artillery Rocket Systems (HIMARS); and three (3) International Field Artillery Tactical Data Systems. The following non-MDE items will also be included: M28A2 Low Cost Reduced Range Practice Rocket Pods; High Mobility Multi-Purpose Wheeled Vehicle Fire Direction Centers; M1084A3 HIMARS resupply vehicles; HIMARS Driver Vision Enhancer systems; AN/PSN-13 Defense Advanced GPS Receiver; support and test equipment; simulators; generators; integration and test support; spares and repair parts; communications equipment; software delivery and support; facilities and construction support; publications and technical documentation; personnel training and training equipment; support equipment; U.S. Government and contractor engineering, technical, and logistics support services; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $500 million. The principal contractor will be Lockheed Martin, located in Grand Prairie, TX. 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
August 19, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Australia has requested to buy one hundred sixty-one (161) Lightweight Command Launch Units (LwCLU) 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 $6.3 million ($0 in Major Defense Equipment (MDE)), included Javelin Life Cycle Support (LCS) and U.S. Government and contractor technical assistance. This notification is for one hundred sixty-one (161) Lightweight Command Launch Units (LwCLU). The following non-MDE items will also be included: Javelin LwCLU Basic Skills Trainer; missile simulation rounds and battery coolant unit; electronic technical manual and operator manuals; life cycle support; physical security inspection; spare parts; System Integration and Check Out; U.S. Government and contractor technical assistance, engineering, logistics, and personnel services; tool kits; training; and other related elements of logistics and program support. The estimated total cost is $97.3 million. The principal contractors will be the Javelin Joint Venture between RTX Corporation, located in Arlington, VA; and Lockheed Martin, located in Orlando, FL. 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 United Kingdom
August 26, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the United Kingdom has requested to buy equipment and services to support contractor logistics support sustainment for the United Kingdom’s C-17 (Globemaster III) aircraft fleet. The following non-MDE items will be included: engine components, parts, and accessories; major and minor modifications; computer program identification numbers; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; 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 $861 million. The principal contractor will be The Boeing Company, located in Arlington, 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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DSCA Notifies Congress of Potential FMS Sale To Poland
August 26, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy equipment and services in support of F-35 sustainment, including the aircraft engine Component Improvement Program (CIP). The following non-MDE items will be included: major and minor modifications; spare parts, consumables and accessories, and repair and return support; weapon system support, including software; classified software and delivery support; classified and unclassified publications and technical documentation; clothing, textiles, and individual equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.85 billion. The principal contractor will be General Electric Aerospace, located in Evendale, OH. 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 Ukraine
August 28, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy up to three thousand three hundred fifty (3,350) Extended Range Attack Munition (ERAM) missiles and three thousand three hundred fifty (3,350) Embedded Global Positioning System (GPS)/Inertial Navigation Systems (INS) (EGI) with Selective Availability Anti-Spoofing Module (SAASM), Y-Code, or M-Code. The following non-MDE items will be included: missile containers; stoker pylons; component parts and support equipment; spare parts, consumables and accessories, and repair and return support; weapons software and support equipment; mission planning system hardware; classified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; 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 $825 million. The principal contractors will be Zone 5 Technologies and CoAspire. 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 Ukraine
August 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services to support sustainment of its Patriot air defense systems. The following non-MDE items will be included: classified and unclassified spare parts; maintenance support; classified and unclassified software and software updates; system modifications and associated modification kits; test equipment; communication equipment and associated accessories; integration services; repair and return; storage; tooling; Field Surveillance Program; International Engineering Services Program; maintenance support equipment; U.S. Government and contractor representative technical assistance; training; engineering and logistics support services; classified and unclassified publications and technical documentation; classified software; and other related elements of logistics and program support. The estimated total program cost is $179.1 million. The principal contractors will be RTX Corporation, located in Arlington, VA; 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 Ukraine
August 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy an extension of satellite communications services for its Starlink terminals. The following non-MDE items will be included: 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 $150 million. The principal contractor for this effort will be Starlink Services, located in Hawthorne, CA. 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 Denmark
August 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Denmark has requested to buy thirty-six (36) PATRIOT MIM-104E guidance enhanced missile-tactical (GEM-T) ballistic missiles; twenty (20) PATRIOT Advanced Capability-3 (PAC-3) Missile Segment Enhancement (MSE) missiles; two (2) AN/MPQ-65 radar sets; two (2) Engagement Control Stations (ECS); two (2) Radar Interface Units (RIU) modification kits; six (6) PATRIOT M903A2 launching stations (LS); six (6) Integrated Battle Command System (IBCS) Software Launcher Integrated Network Kits (LINKs); two (2) IBCS Engagement Operations Centers (EOCs); two (2) IBCS Integrated Collaborative Environments (ICE); six (6) IBCS integrated fire control network (IFCN) relays; and two (2) Electrical Power Plants III (EPP III). The following non-MDE items will also be included: communications equipment including, but not limited to, AN/TPX–57A identification friend or foe (IFF), Defense Advanced Global Positioning System (GPS) Receiver (DAGR), AN/PYQ-10 Simple Key Loader, KIV-77 encryptor, KG-250X Inline Network Encryptor, IPS-250X HAIPE Encryptor, future Combat Net Radio, and AN/PRC-163 radio; tools and test equipment; support equipment; generators; publications and technical documentation; training equipment including the Air Defense Reconfigurable Trainer; spare and repair parts; personnel training; Technical Assistance Field Team support; U.S. Government and contractor technical assistance and services, engineering, and logistics support; System Integration and Checkout; field office support; and other related elements of logistics and program support. The estimated total cost is $8.5 billion. The principal contractors will be RTX Corporation, located in Arlington, VA; Lockheed-Martin, located in Dallas, TX; and Northrop Grumman, located in Falls Church, 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)
August 19, 2025: 90 Fed. Reg. 40326: The Department of Commerce announced the addition of 407 product categories to the list of “derivative” steel and aluminum products covered by Section 232 sectoral tariffs. As a result, the steel and aluminum content of these products will be subject to a duty rate of 50%. This action covers wind turbines and their parts and components, mobile cranes, bulldozers and other heavy equipment, railcars, furniture, compressors and pumps, and hundreds of other products.
Under Secretary of Commerce for Industry and Security Jeffrey Kessler stated:
“This action expands the reach of the steel and aluminum tariffs and shuts down avenues for circumvention – supporting the continued revitalization of the American steel and aluminum industries.”
This is the latest in a series of historic steps by the Trump Administration to strengthen America’s steel and aluminum industry. In February, President Trump issued Proclamations 10895 and 10986, which eliminated numerous carve-outs from the Section 232 steel and aluminum tariffs and cracked down on tariff misclassification and duty evasion schemes. These proclamations also directed Commerce, within 90 days, to establish a process for adding steel and aluminum derivative products to the Section 232 tariffs – which Commerce did in May. In June, President Trump issued Proclamation 10947, which increased the tariff rate for steel and aluminum from 25% to 50%, making the tariffs stronger than ever.
Under Commerce’s steel and aluminum product inclusion process, there are three annual windows for the public to submit product inclusion requests. The next window will open in September and will be announced in the Federal Register.
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Commerce Eases Export Controls on Syria
August 28, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) published a rule easing licensing requirements for civilian exports to Syria.
The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025). EO 14312 declared the United States’ commitment to supporting a Syria that is stable, unified, and at peace with itself and its neighbors. EO 14312 called for the removal of sanctions on Syria, and it also issued waivers that allow for the relaxation of export controls on Syria.
As a result of this rule, U.S.-origin goods, software, and technology that have purely civilian uses (i.e., those classified under BIS’s regulations as “EAR99”), as well as consumer communications devices and certain items related to civil aviation, can generally go to Syria without an export license. In addition, this rule facilitates the approval of licenses for exports to Syria related to telecommunications infrastructure, sanitation, power generation, and civil aviation. All other applications for exports of dual-use items to Syria will be reviewed on a case-by-case basis. BIS will continue to restrict exports when the end-users of items are malign actors, including certain Syrian individuals and entities that remain subject to sanctions.
https://media.bis.gov/press-release/commerce-eases-export-controls-syria
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Department of Commerce Closes Export Controls Loophole for Foreign-Owned Semiconductor Fabs in China
August 29, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) closed a Biden-era loophole that allowed a handful of foreign companies to export semiconductor manufacturing equipment and technology to China license-free. Now these companies will need to obtain licenses to export their technology, putting them on par with their competitors.
The loophole is known as the Validated End-User (VEU) program. In 2023, the Biden Administration expanded the VEU program to allow a select group of foreign semiconductor manufacturers to export most U.S.-origin goods, software, and technology license-free to manufacture semiconductors in China. No U.S.-owned fab has this privilege — and now, following this decision, no foreign-owned fab will have it either.
Former VEU participants will have 120 days following publication of the rule in the Federal Register to apply for and obtain export licenses. Going forward, BIS intends to grant export license applications to allow former VEU participants to operate their existing fabs in China. However, BIS does not intend to grant licenses to expand capacity or upgrade technology at fabs in China.
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U.S. Census Bureau
Foreign Trade Regulations: Clarification of Filing Requirements Regarding In-transit Shipments and other Foreign Trade Regulations Provisions
August 14, 2025: The Census Bureau’s Economic Management Division (EMD) announced the publication of a Final Rule which provides instructions when foreign goods enter the U.S. for consumption or warehousing and are subsequently exported. Additionally, this proposed rule revises several sections, including definitions, mandatory filing requirements, responsibilities of parties to the export transaction, confidentiality, penalty provisions, and voluntary self-disclosures to ensure clarity, accuracy, and consistency throughout the FTR.
The Final Rule can be found in its entirety at Federal Register: Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions
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Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions
August 14, 2025: 90. Fed. Reg. 39112: The Bureau of the Census (Census Bureau) issues this final rule to clarify its regulations governing in-transit shipments from foreign countries through the United States that are subsequently exported to a foreign destination. Specifically, the final rule addresses the identification of the U.S. Principal Party in Interest (USPPI) in scenarios where goods are entered into the United States for consumption or warehousing and subsequently stored in a warehouse or storage facility, admitted into a Foreign Trade Zone (FTZ), or entered into a bonded warehouse before being exported. The rule establishes clear guidelines for different parties involved in export transactions. For customs brokers serving as the USPPI, the regulation notes obtaining client consent to provide customs entry information for Electronic Export Information (EEI) filing is required per customs regulations. Similarly, when a warehouse, storage facility, FTZ, or bonded warehouse operator acts as the USPPI, they are responsible for the EEI based on information they possess or have received from other parties to the export transaction. Additionally, this final rule revises several regulatory sections, including definitions, mandatory filing requirements, responsibilities of parties to the export transaction, confidentiality protocols, penalty provisions, and voluntary self-disclosure processes to ensure greater clarity, accuracy, and consistency throughout the FTR.
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Upcoming Changes to AESDirect for State of Origin
August 15, 2025: This message is a follow-up to the broadcast that was released on August 14, 2025, titled Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-transit Shipments and other FTR Provisions. In the final rule the U.S. Census Bureau changed the name of the “Address of the USPPI” to “Address of Origin”. As a result, the field names under the USPPI section in AESDirect will change to the following:
| Current Field Names | New Field Names After Change |
| Address – Line 1 | Address of Origin – Line 1 |
| Address – Line 2 | Address of Origin – Line 2 |
| Postal Code | Postal Code of Origin |
| City | City of Origin |
| State | State of Origin |
The USPPI Address and State of Origin fields are defined identically—both require the filer to report the location where goods begin their journey to the port of export and as a result these fields should match. We are changing the field names to clarify that the USPPI address represents the origin of movement, not the address associated with the USPPI EIN or headquarters address. The updates to the field names will be active in AESDirect on August 19, 2025 after 2:00pm EDT.
Additionally, there will be front-end edits added in AESDirect that will validate matching information for the State of Origin in the USPPI section in Step 2 compared to the State of Origin reported in Step 1. Filers must ensure the full address is updated and reported as the location from which the goods actually begin the journey to the port of export as defined in section 30.6(a)(1)(ii) and 30.6(a)(4) of the FTR.
Note for Template and Profile Users: Filers must edit or delete any existing Shipment Templates or Party Profiles in AESDirect that may include incorrect USPPI Address information. As a reminder, the Shipment Template Manager and Party Profile Manager can be found under the ‘Tools Menu’ located at the top right of your Shipment Manager screen. For instructions on managing Shipment Templates and Party Profiles, please refer to the ACE AESDirect User Guide.
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How to Resolve Common AES Response Messages
August 18, 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: 8W1
Narrative: Shipping Weight/Quantity 1 Out of Range
Severity: Verify
Reason: For the reported Schedule B/HTS Number, the Shipping Weight/Quantity (1) ratio is outside of the expected range.
Resolution: For a particular Schedule B/HTS Number reported, the shipping weight divided by the first quantity should fall within a certain parameter based on historical statistical averages for that commodity. Ratios outside this pre-determined parameter might indicate either a keying error or misclassification of the product.
Verify the Shipping Weight, Quantity 1, and Schedule B/HTS Number, correct the shipment and resubmit (if necessary). If the line item is verified correct as reported, no action is necessary.
For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.
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)
August 18, 2025: In federal court in Brooklyn, dual U.S. and Russian national Vadim Yermolenko was sentenced by United States District Judge Hector Gonzalez to 30 months in prison for his role in an illicit procurement and money laundering network that sought to acquire ammunition and sensitive dual-use electronics for Russian military and intelligence services. In addition to the term of imprisonment, Judge Gonzalez ordered Yermolenko to pay a forfeiture money judgment of $75,547.00. Yermolenko pleaded guilty in November 2024 to conspiracy to violate the Export Control Reform Act, bank fraud conspiracy, and conspiracy to defraud the United States.
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August 21, 2025: At the federal courthouse in Brooklyn, an eight-count indictment was unsealed charging Maxim Larin for his involvement in a scheme to illegally export weapons parts and accessories from the United States to other countries, including Kazakhstan, which serve as transshipment points for materials destined for Russia. The indictment charges Larin with conspiracy to defraud the United States, conspiracy to violate the Export Control Reform Act, conspiracy to violate the Arms Export Control Act, attempted violation of the Arms Export Control Act, smuggling goods from the United States, and submission of false export information. Larin was arrested in Plantation, Florida and made his initial appearance in federal court in Miami. He will be arraigned in the Eastern District of New York at a later date.
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August 28, 2025: 90. Fed. Reg. 41969: On June 8, 2023, in the U.S. District Court for the Southern District of Texas, Imelda Jimenez (“Jimenez”) was convicted of violating 18 U.S.C. 554(a). Specifically, Jimenez was convicted of smuggling firearms from the U.S. to Mexico. As a result of her conviction, the Court sentenced Jimenez to 30 months of imprisonment and two years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Jimenez’s export privileges under the Regulations for a period of seven years from the date of Jimenez’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Jimenez had an interest at the time of her conviction.
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August 28, 2025: 90. Fed. Reg. 41970: On May 1, 2024, in the U.S. District Court for the Middle District of Florida, Gabriel Daniel Pinnace (“Pinnace”) was convicted of violating 18 U.S.C. 554(a). Specifically, Pinnace was convicted of smuggling firearms from the U.S. to Venezuela. As a result of his conviction, the Court sentenced Pinnace to 72 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Pinnace’s export privileges under the Regulations for a period of 10 years from the date of Pinnace’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Pinnace had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41978: On May 10, 2021, in the U.S. District Court for the District of Arizona, Francisco Dario Mora (“Mora”) was convicted of (among other crimes) violating 18 U.S.C. 371 and 18 U.S.C. 554(a). Specifically, Mora was convicted of conspiring to smuggle firearms, ammunition and magazines from the United States to Mexico. As a result of his conviction, the Court sentenced Mora to 60 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Mora’s export privileges under the Regulations for a period of 10 years from the date of Mora’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Mora had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41981: On February 14, 2024, in the U.S. District Court for the Western District of Texas, (“Gallegos”) was convicted of violating 18 U.S.C. 554 (a) (Smuggling Goods from the United States). Specifically, Gallegos was convicted of smuggling firearms from the United States to Mexico. As a result of her conviction, the court sentenced Gallegos to 60 months in prison and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Gallegos’s export privileges under the Regulations for a period of 10 years from the date of Gallegos’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gallegos had an interest at the time of her conviction.
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August 28, 2025: 90. Fed. Reg. 41985: On November 30, 2023, in the U.S. District Court for the District of Arizona, Juan Manuel Cervantes-Aceves (“Cervantes-Aceves”) was convicted of violating 18 U.S.C. 554(a). Specifically, Cervantes-Aceves was convicted of smuggling firearms and magazines from the United States to Mexico. As a result of his conviction, the Court sentenced Cervantes-Aceves to four years of probation.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BISI has decided to deny Cervantes-Aceves’s export privileges under the Regulations for a period of 10 years from the date of Cervantes-Aceves’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Cervantes-Aceves had an interest at the time of his conviction
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August 28, 2025: 90. Fed. Reg. 41968: On October 10, 2023, in the U.S. District Court for the District of Arizona, Martina Juanita Gil (“Gil”) was convicted of violating 18 U.S.C. 554(a). Specifically, Gil was convicted of smuggling one thousand (1,000) rounds of .45 caliber ammunition and two thousand (2,000) rounds of 9mm ammunition from the U.S. to Mexico. As a result of her conviction, the Court sentenced Gil to 12 months and one day of imprisonment, with credit for time served, and three years of supervised release.
Based upon BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its Director, and the facts available to BIS, BIS has decided to deny Gil’s export privileges under the Regulations for a period of five years from the date of Gil’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gil had an interest at the time of her conviction.
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August 28, 2025: 90. Fed. Reg. 41972: On November 30, 2023, in the U.S. District Court for the District of Arizona, Guadalupe Gil (“Gil”) was convicted of violating 18 U.S.C. 554(a). Specifically, Gil was convicted of smuggling one thousand (1,000) rounds of .45 caliber ammunition and two thousand (2,000) rounds of 9mm ammunition from the U.S. to Mexico. As a result of his conviction, the Court sentenced Gil to 41 months, with credit for time served, and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Gil’s export privileges under the Regulations for a period of 10 years from the date of Gil’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gil had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41973: On November 17, 2023, in the U.S. District Court for the Southern District of California, Cesar David Piz Corona (“Corona”) was convicted of violating 18 U.S.C. 554(a). Specifically, Corona was convicted of smuggling a Springfield Armory XDm 9mm handgun and a Beretta M9 from the United States to Mexico. As a result of his conviction, the Court sentenced Corona to 21 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Corona’s export privileges under the Regulations for a period of five years from the date of Corona’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Corona had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41977: On June 11, 2024, in the U.S. District Court for the District Southern of Texas, Jose Guadalupe Mejia (“Mejia”) was convicted of violating 18 U.S.C. 554(a). Specifically, Mejia was convicted of attempting to export 701 rounds of assorted ammunition from the United States to Mexico, without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the Court sentenced Mejia to 46 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Mejia’s export privileges under the Regulations for a period of 10 years from the date of Mejia’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Mejia had an interest at the time of his conviction.
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August 29, 2025: 90. Fed. Reg. 41979: On December 5, 2023, in the U.S. District Court for the Southern District of Georgia, Prince Bediako (“Bediako”) was convicted of violating 18 U.S.C. 554. Specifically, Bediako was convicted of smuggling fraudulently obtained vehicles from the United States to Ghana. As a result of his conviction, the Court sentenced Bediako to 28 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Bediako’s export privileges under the Regulations for a period of seven years from the date of Bediako’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Bediako had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41980: On July 12, 2024, in the U.S. District Court for the Northern District of Georgia, Kamir Armando Brown Blanchard (“Blanchard”) was convicted of violating 18 U.S.C. 554. Specifically, Blanchard was convicted of unlawfully exporting firearms from the U.S. to Panama. As a result of his conviction, the Court sentenced Blanchard to 36 months of imprisonment and one year of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Blanchard’s export privileges under the Regulations for a period of 10 years from the date of Blanchard’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Blanchard had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41972: On August 31, 2023, in the U.S. District Court for the Southern District of Texas, Pedro Cruz Almeida, Jr. (“Almeida”) was convicted of violating 18 U.S.C. 554(a) (Smuggling Goods from the United States). Specifically, Almeida was convicted of smuggling nine hundred (900) rounds of Lake City .50 caliber tracer-equipped linked ammunition, from the United States to Mexico, without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the court sentenced him to 50 months in prison and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Almeida’s export privileges under the Regulations for a period of 10 years from the date of Almeida’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Almeida had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41974: On July 17, 2024, in the U.S. District Court for the District Southern of New York, Maxim Marchenko (“Marchenko”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Marchenko was convicted of unlawfully causing companies in the United States to export OLED micro-displays from the United States to Russia. Marchenko was also convicted of conspiracy to commit money laundering. As a result of his convictions, the Court sentenced Marchenko to 36 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Marchenko’s export privileges under the Regulations for a period of ten (10) years from the date of Marchenko’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Marchenko had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41978: On April 18, 2024, in the U.S. District Court for the Southern District of Texas, Jessica Alvarado (“Alvarado”) was convicted of violating 18 U.S.C. 554(a). Specifically, Alvarado was convicted of smuggling thirty-three 7.62×39 caliber rifles, three 5.56 caliber rifles, one Ruger .22 caliber carbine rifle, two .45 caliber pistols, and thirty-nine ammunition magazines from the U.S. to Mexico, without a license or written approval from the U.S. Department of Commerce. As a result of her conviction, the Court sentenced Alvarado to 46 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Alvarado’s export privileges under the Regulations for a period of 10 years from the date of Alvarado’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Alvarado had an interest at the time of her conviction.
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August 28, 2025: 90. Fed. Reg. 41982: On May 16, 2024, in the U.S. District Court for the Southern District of Texas, Damian Alejandro Vidal (“Vidal”) was convicted of violating 18 U.S.C. 554(a). Specifically, Vidal was convicted of smuggling one Sig Sauer, model 1911 .45 caliber handgun and one Glock, model 19, 9mm handgun, from the U.S. to Mexico, without having first obtained the required licenses. As a result of his conviction, the Court sentenced Vidal to 40 months in prison and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Vidal’s export privileges under the Regulations for a period of eight years from the date of Vidal’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Vidal had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41984: On August 6, 2024, in the U.S. District Court for the Southern District of New York, Miguel Barrera (“Barrera”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States) and 18 U.S.C. 1956(a)(2) (Money Laundering). With respect to the smuggling count, specifically, Barrera was convicted of concealing and exporting from the United States, and attempting to export from the United States, firearms and firearms components, knowing that the export of such firearms and firearms components was contrary to law. As a result of his conviction, the Court sentenced Barrera to 80 months of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Barrera’s export privileges under the Regulations for a period of 10 years from the date of Barrera’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Barrera had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41971: On April 30, 2024, in the U.S. District Court for the Eastern District of New York, Vladimir Kuznetsov (“Kuznetsov”) was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778) (“AECA”). Specifically, Kuznetsov was convicted of knowingly and willfully exporting and attempting to export from the United States to Russia without obtaining required U.S. government authorization rifle parts and accessories designated as defense articles on the United States Munitions List, to wit: one Accuracy International AICS AX MK II rifle chassis, one “H-S Precision” aluminum rifle stock, one “Kinetic Research Group” savage 180-Alpha rifle chassis, one Dakota bolt shroud, one Timney Sportsman trigger assembly, multiple firearm magzines, and other firearms accessories. As a result of his conviction, the Court sentenced Kuznetsov to 46 months in prison and two years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Kuznetsov’s export privileges under the Regulations for a period of 10 years from the date of Kuznetsov’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Kuznetsov had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41975: On March 29, 2024, in the U.S. District Court for the Northern District of California, Fares Abdo Al Eyani (“Al Eyani”) was convicted of violating 18 U.S.C. 371 and Section 38 of the Arms Export Control Act (22 U.S.C. 2778) (“AECA”). Specifically, Al Eyani was convicted of conspiring and attempting to illegally export or cause to be exported defense articles to the Sultanate of Oman, without an export license, and in knowing and willful violation of the AECA and the International Traffic in Arms Regulations. As a result of his conviction, the Court sentenced Al Eyani to 12 months and one day of imprisonment and three years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Al Eyani’s export privileges under the Regulations for a period of ten (10) years from the date of Al Eyani’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Al Eyani had an interest at the time of his conviction.
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August 28, 2025: 90. Fed. Reg. 41983: On June 21, 2024, in the U.S. District Court for the Middle District of Florida, Chrissie Fier Williams (“Williams”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Willaims was convicted of attempting to export or send firearms, firearms parts and components, and ammunition from the United States to Trinidad & Tobago without required authorization. As a result of his conviction, the Court sentenced Williams to 37 months of imprisonment and two years of supervised release.
Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Williams’s export privileges under the Regulations for a period of 10 years from the date of Williams’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Williams had an interest at the time of his conviction.
Sanctions
Department of State, Directorate of Defense Trade Controls (DDTC)
August 22, 2025: 90 Fed. Reg. 40458: Pursuant to section 38(g)(4) of the AECA and section 127.7(b) and (c)(1) of the ITAR, the following persons, having been convicted in a U.S. District Court, are denied export privileges and are statutorily debarred as of the date of this notice (Name; Date of Judgment; Judicial District; Case No.; Month/Year of Birth):
- Aldalawi, Rawnd Khaleel; January 11, 2019; Western District of Washington; 2:18-cr-00025; April 1988;
- Chan, Lionel; June 1, 2021; District of Massachusetts; 1:19-cr-10064; August 1983;
- Cox, Michael; May 27, 2021; Western District of Pennsylvania; 2:18-cr-00050; May 1975;
- Duroseau, Jacques Yves Sebastien; March 2, 2021; Eastern District of North Carolina; 4:20-cr-3; May 1986;
- Garza-Solis, Jacobo Javier; November 4, 2020; Southern District of Texas; 7:17-cr-00360; December 1996;
- Issa, Jean Youssef; December 20, 2023; Northern District of Ohio; 1:16-cr-00102; June 1974;
- Koyshman, Josef; February 7, 2020; District of Columbia; 1:19-cr-00267; June 1967;
- Kuznetsov, Vladimir; May 1, 2024; Eastern District of New York; 1:21-cr-00099; October 1961;
- Man, Cho Yan Nathan; a.k.a Nathan Man; May 19, 2020; District of Columbia; 1:19-cr-00218; December 1985;
- Palomares, Jr., Rafael; May 13, 2021; District of Arizona; 2:19-cr-00089; July 1989;
- Radzi, Muhammad Mohd; June 1, 2021; District of Massachusetts; 1:19-cr-10064; June 1993;
- Rhoomes, Jermaine Craig; a.k.a. Rhoomas, Jermain; a.k.a. Rhoomas, Jermaine Craig; a.k.a. Rhooms, Jermaine; a.k.a. Hall, Craig; a.k.a. Hall, Kreig; a.k.a. Cow; February 5, 2020; Middle District of Florida; 8:19-cr-00078; April 1973;
- Rincon-Avilez, Gardenia Marlene; December 16, 2024; District of Arizona; 4:18-cr-01141; July 1986;
- Schultz, Korbein; April 28, 2025; Middle District of Tennessee; 3:24-cr-00056; May 1999;
- Senbol, Yuksel; October 31, 2024; Middle District of Florida, 8:23-cr-00384; May 1987;
- Shifrin, Elena; a.k.a Belov, Alexander; a.k.a Ivanov, Lena; a.k.a Gohkman, Elena; a.k.a. Elena Leonidovna Shifrin; July 23, 2024; Central District of California; 2:21-cr-00259; February 1962; and
- Stashchyshyn, Michael; July 20, 2021; Western District of Pennsylvania; 2:18-cr-00050; July 1962.
At the end of the three-year period following the date of this notice, the above-named persons remain debarred unless a request for reinstatement from statutory debarment is approved by the Department of State.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
August 6, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three high-ranking members and one prominent associate of the Mexico-based Cartel del Noreste (CDN), formerly known as Los Zetas. CDN, one of the most violent drug trafficking organizations in Mexico, is a U.S.-designated Foreign Terrorist Organization (FTO) that exerts significant influence over the U.S.-Mexico border, specifically the Laredo, Texas point of entry. CDN’s influence in the Mexican border cities of Nuevo Laredo, Tamaulipas and Piedras Negras, Coahuila, has affected communities on both sides of the border, and the cartel’s role in fentanyl trafficking and human smuggling into the United States puts American lives at risk. The individuals being designated play key roles in aiding CDN’s horrific crimes, including assassinations, beheadings, drug trafficking, extortion, and money laundering.
The following individuals have been added to OFAC’s SDN List:
- Esqueda Nieto, Francisco Daniel of Mexico;
- Hernandez Medrano, Ricardo of Mexico;
- Rodriguez Garcia, Abdon Federico of Mexico; and
- Romero Sanchez, Antonio of Mexico.
https://ofac.treasury.gov/recent-actions/20250806 and
https://home.treasury.gov/news/press-releases/sb0219
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August 7, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 18 entities and individuals that play pivotal roles in the Iranian regime’s efforts to generate revenue and circumvent U.S. sanctions. Facing severe financial constraints due to international isolation, Iran has engineered sophisticated banking schemes and alternate payment messaging systems specifically designed to bypass sanctions and protect its ability to collect export revenues, particularly from illicit petroleum sales. These systems also enable the regime’s continued funding of its proxies and oppression of the Iranian people. Additionally, financial and information technology firms designated have provided the regime with advanced surveillance technologies that Iran’s security services deploy to restrict internet access and to target women who violate the regime’s mandatory hijab restrictions.
The following individuals have been added to OFAC’s SDN List:
- Berjisian, Adel of Iran;
- Birang, Ali Morteza of Iran;
- Fatahinojokambari, Alireza of Iran;
- Javanmardi, Shahab of Iran;
- Nouri, Hadi of Iran;
- Sajjadi, Seyyed Mahmoud Reza of Iran; and
- Shafipour, Mohammad of Iran.
The following entities have been added to OFAC’S SDN List:
- Arian Pasargad Communications and Information Technology Ecosystem Development Company of Iran;
- Arian Pasargad Communications and Information Technology Infrastructure Company of Iran;
- Arman Kish Data Communications and Information Technology Company of Iran;
- Arvand Arian Pasargad Communications and Information Technology Payment Company of Iran;
- Cyrus Offshore Bank of Iran;
- Pasargad Arian Information and Communication Technology Company of Iran;
- Pasagrad Electronic Payment Services Company of Iran;
- Qeshim Arian Datis Sofrtware Company of Iran;
- Rashid Samaneh Electronic Processing Company of Iran;
- Runc Exchange Systems Company of Iran; and
- Sherkat-E Barid Fanavar Arian of Iran.
https://ofac.treasury.gov/recent-actions/20250807 and
https://ofac.treasury.gov/recent-actions/20250807
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August 11, 2025: The Department of State designated The Balochistan Liberation Army (BLA) and its alias, The Majeed Brigade, as a Foreign Terrorist Organization (FTO), and added the Majeed Brigade as an alias to BLA’s previous Specially Designated Global Terrorist (SDGT) designation.
The following changes have been made to OFAC’s SDN List:
- Balochistan Liberation Army of Pakistan.
https://ofac.treasury.gov/recent-actions/20250811
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August 12, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on entities linked to armed group violence and the sale of critical minerals in the Democratic Republic of the Congo (DRC). Eastern DRC has experienced thousands of civilian deaths and a mass displacement crisis due to ongoing instability, which has been exacerbated recently by the Rwanda-backed March 23 Movement’s (M23) territorial control and reprisal attacks from DRC-aligned militias. M23, a U.S.- and United Nations-designated armed group, has rapidly expanded its territorial control in eastern DRC and is responsible for human rights abuses.
The following entities have been added to OFAC’s SDN List:
- Coalition of Congolese Patriotic Resistance-Force De Frappe of the Democratic Republic of the Congo;
- Cooperative Des Artisanaux Miniers Du Congo of the Democratic Republic of the Congo;
- East Rise Corporation Limited of the Democratic Republic of the Congo; and
- Star Dragon Corporation Limited of the Democratic Republic of the Congo.
https://ofac.treasury.gov/recent-actions/20250812 and
https://ofac.treasury.gov/recent-actions
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August 13, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 125, “Authorizing Transactions Related to Meetings Between the Government of the United States of America and the Government of the Russian Federation in Alaska.”
GENERAL LICENSE NO. 125: “Authorizing Transactions Related to Meetings Between the Government of the United States of America and the Government of the Russian Federation in Alaska”
- All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR), that are ordinarily incident and necessary to the attendance at or support of meetings in the State of Alaska between the Government of the United States of America and the Government of the Russian Federation are authorized through 12:01 a.m. eastern daylight time, August 20, 2025.
https://ofac.treasury.gov/recent-actions/20250813_33 and
https://ofac.treasury.gov/media/934566/download?inline
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August 13, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four Mexican individuals and 13 Mexican companies linked to timeshare fraud led by the Cartel de Jalisco Nueva Generacion (CJNG). These individuals and companies are based in or near Puerto Vallarta, a popular tourist destination that also serves as a strategic stronghold for CJNG. A brutally violent cartel, CJNG is a U.S.-designated Foreign Terrorist Organization (FTO) that is increasingly supplementing its drug trafficking proceeds with alternative revenue streams such as timeshare fraud and fuel theft.
The following individual has been added to OFAC’s SDN List:
- Ibarra Biaz Jr, Michael of Mexico.
The following entities have been added to OFAC’s SDN List:
- Akali Realtors of Mexico;
- Centro Mediador De La Costa, S.A. DE C.V. of Mexico;
- Consultorias Profesionales Almida, S.A. of Mexico;
- Corporative Costa Norte, S.A. DE C.V., of Mexico;
- Corporativo Integral De La Costa, S.A. DE C.V. of Mexico;
- Fishing Are US, S. DE R.L. DE C.V. of Mexico;
- Inmobiliaria Integral Del Puerto, S.A. DE C.V. of Mexico;
- KVY Bucerias, S.A. DE C.V. of Mexico;
- Laminado Profesional Automotriz Elte, S.A. DE C.V. of Mexico;
- Santamaria Cruise, S. DE R.L. DE C.V. of Mexico;
- Servicios Inmobiliarios Ibadi, S.A. DE C.V. of Mexico;
- Sunmex Travel, S. DE C.V. of Mexico; and
- TTR Go, S.A. of Mexico.
https://ofac.treasury.gov/recent-actions/20250813
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August 14, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) re-designated the cryptocurrency exchange Garantex Europe OU (Garantex), which has directly facilitated notorious ransomware actors and other cybercriminals by processing over $100 million in transactions linked to illicit activities since 2019. OFAC also designated Garantex’s successor, Grinex, and taking action against three executives of Garantex and six associated companies in Russia and the Kyrgyz Republic that have supported the exchange’s involvement in malicious cyber activities.
The following individuals have been added to OFAC’s SDN List:
- Karavatsky, Pavel of Russia;
- Mendeleev, Sergey of Russia; and
- Mira Serda, Aleksandr Khoseluisovich of Russia.
The following entities have been added to OFAC’s SDN List:
- A7 Agent Limited Liability Company of Russia;
- A7 Limited Liability Company of Russia;
- A71 Limited Liability Company of Russia;
- Exved of Russia;
- Grinex of Russia;
- Independent Decentralized Finance Smartbank and Ecosystem of Russia; and
- Old Vector LLC of Russia.
https://home.treasury.gov/news/press-releases/sb0225 and
https://ofac.treasury.gov/recent-actions/20250814
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August 14, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two notorious Mexican cartels—Carteles Unidos (a.k.a. “United Cartels”) and Los Viagras—and seven affiliated individuals linked to terrorism, drug trafficking, and extortion in Mexico’s agricultural sector. Treasury’s action, taken pursuant to counternarcotics and counterterrorism authorities, further implements President Trump’s directive to eliminate completely cartels and transnational criminal organizations threatening the American people.
The following individuals have been added to OFAC’s SDN List:
- Barragan Chavez, Luis Enrique of Mexico;
- Flores, Heladio Cisneros of Mexico;
- Alvarez, Juan Jose Farias of Mexico;
- Fernandez, Magallon of Mexico;
- Orozco Cabada, Edgar Valeriano of Mexico;
- Sepulveda Arellano, Cesar Alejandro of Mexico; and
- Sierra Santana, Nicolas.
https://ofac.treasury.gov/recent-actions/20250814 and
https://home.treasury.gov/news/press-releases/sb0224
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August 18, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Costa Rican nationals, as well as two Costa Rica-based entities, for their involvement in narcotics trafficking and money laundering. A key global cocaine transshipment hub, Costa Rica has become an increasingly significant waypoint for criminal groups trafficking cocaine into the United States. According to the Drug Enforcement Administration (DEA), cocaine continues to pose a serious threat to the public, causing over 22,000 overdose deaths in the United States in the 12-month period ending in October 2024.
The following individuals have been added to OFAC’s SDN List:
- Arias Monge, Alejandro of Cota Rica;
- Gamboa Sanchez, Celso Manuel of Costa Rica;
- James Wilson, Alejandro Antonio of Costa Rica; and
- Lopez Vega, Edwin Danney of Costa Rica.
The following entities have been added to OFAC’s SDN List:
- Bufete Celso Gamboa and Asociados of Costa Rica; and
- Limon Black Star FC of Costa Rica.
https://ofac.treasury.gov/recent-actions/20250818 and
https://home.treasury.gov/news/press-releases/sb0227
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August 20, 2025: The United States sanctioned four individuals, currently serving on the International Criminal Court (ICC). The Department of State’s designations are made pursuant to Executive Order (E.O.) 14203, which authorizes sanctions on foreign persons engaged in certain malign efforts by the ICC and aims to impose tangible and significant consequences on those directly engaged in the ICC’s transgressions against the United States and Israel.
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued International Criminal Court-related General License 9, “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on August 20, 2025.”
GENERAL LICENSE NO. 9: “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on August 20, 2025”
(a) All transactions prohibited by the International Criminal Court-Related Sanctions Regulations (ICCSR), 31 CFR part 528, that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern daylight time, September 19, 2025, provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States, in accordance with the ICCSR:
(1) Nicolas Yann Guillou;
(2) Nazhat Shameem Khan;
(3) Mame Mandiaye Niang;
(4) Kimberly Prost; or
(5) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
The following individuals have been added to OFAC’s SDN List:
- Guillou, Nicolas Yann of France;
- Khan, Nazhat Shameen of Fiji;
- Niang, Mame Mandiaye of Senegal; and
- Prost, Kimberly of Canada.
https://ofac.treasury.gov/recent-actions/20250820
https://ofac.treasury.gov/media/934581/download?inline
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August 21, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) further disrupted Iran’s oil exports by imposing sanctions on Greek national Antonios Margaritis, his network of companies, and nearly a dozen vessels involved in Iran’s shadow fleet. Margaritis has leveraged his decades of experience in the shipping industry to illicitly facilitate the transportation and sale of Iranian petroleum. Several other vessels and operators are also being designated for their role facilitating Iranian oil exports, which generates revenue that contributes to Iran’s advanced weapons programs.
The following individual has been added to OFAC’s SDN List:
- Margatis, Antonios of Greece.
The following entities have been added to OFAC’s SDN List:
- Ares Shipping Limited of China;
- Comford Management S.A. of the Marshall Islands;
- Cristobal Marine Corp of the Marshall Islands;
- Hong Kong Hangshun Shipping Limited of China;
- Marant Shipping and Trading S.A. of Greece;
- Ozarka Shipping – FZCO of the United Arab Emirates;
- Qingdao Port Haiye Dongjiakou Oil of China;
- Regal Liberty Limited of China;
- Square Tanker Management Ltd. of the Marshall Islands;
- U Beacon Shipping Co., Limited of China;
- United Chartering S.A. of the Marshall Islands; and
- Yangshan Shengang International Petroleum Storage and Transportation Co., Ltd of China.
The following vessels have been added to OFAC’s SDN List:
- Adeline G 3E3513) Crude Oil Tanker Panama flag; MMSI 352002297 (vessel);
- Ares (E5U3903) Crude Oil Tanker Cook Islands flag; MMSI 518100992 (vessel);
- Giant (a.k.a. MACHO QUEEN) (VRUF3) Crude Oil Tanker Hong Kong flag; MSI 477722100 (vessel);
- Katsuya (C5J502) Oil Products Tanker Gambia flag; MMSI 629009490 (vessel);
- Kongm (3E5132) Crude Oil Tanker Panama flag; MMSI 353529000 (vessel);
- Lafit (S9A3169) Crude Oil Tanker Sao Tome & Principe flag; MMSI 668116369 (vessel);
- Sondos (V2YL4) Chemical/Oil Tanker Antigua and Barbuda flag; MMSI 305263000 (vessel); and
- Victory Ari (V2YR4) Chemical/Oil Tanker Antigua and Barbuda flag; MMSI 305049000 (vessel).
https://ofac.treasury.gov/recent-actions/20250821
https://home.treasury.gov/news/press-releases/sb0229
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August 25, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Syrian Sanctions Regulations to remove them from the Code of Federal Regulations, consistent with Executive Order 14312 of June 30, 2025, “Providing for the Revocation of Syria Sanctions.” This regulatory amendment is currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on August 26, 2025.
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August 27, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Vitaliy Sergeyevich Andreyev, Kim Ung Sun, Shenyang Geumpungri Network Technology Co., Ltd, and Korea Sinjin Trading Corporation for their roles in a fraudulent information technology (IT) worker scheme orchestrated by the Democratic People’s Republic of Korea (DPRK) government.
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 104A, “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068.”
GENERAL LICENSE NO. 104A: “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068”
(a) All transactions prohibited by the determination of February 8, 2024 made pursuant to section 1(a)(i)(B) of Executive Order (E.O.) 14068 (“Prohibitions Related to Imports of Certain Categories of Diamonds”) that are ordinarily incident and necessary to the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of the following categories of diamonds are authorized through 12:01 a.m. eastern daylight time, September 1, 2026, provided that the diamonds were physically located outside of the Russian Federation before, and were not exported or re-exported from the Russian Federation since:
(1) March 1, 2024 for non-industrial diamonds with a weight of 1.0 carat or greater; or
(2) September 1, 2024 for non-industrial diamonds with a weight of 0.5 carats or greater.
https://ofac.treasury.gov/media/934591/download?inline
The following individuals have been added to OFAC’s SDN List:
- Andreyev, Vitaly Sergeyevich of Russia; and
- Kim, Ung Sun of North Korea.
The following entities have been added to OFAC’s SDN List:
- Korea Sinjin Trading Corporation of North Korea; and
- Shenyang Geumpungri Network Technology Co., Ltd of China.
https://ofac.treasury.gov/recent-actions/20250827