This newsletter is a listing of the latest changes in export control regulations through March 31, 2026.  The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

 

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

persons denied export privileges by the United States Government.

 

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

 

 

REGULATORY UPDATES

 

President

 

White House Unveils Cyber Strategy for America

 

March 6, 2026: The White House released “Cyber Strategy for America,” outlining the Administration’s priorities for ensuring that America remains unrivaled in cyberspace. It calls for unprecedented coordination across government and the private sector to invest in the best technologies and continue world-class innovation, and to make the most of America’s cyber capabilities for both offensive and defensive missions.

 

This strategy communicates the Administration’s cyber vision and approach to the American people, to Congress, to our partners in industry and allies across the globe—and also to adversaries. It explains the Administration’s priorities, summarized in six policy pillars, which will guide action and resourcing through the follow-on policy vehicles.

 

https://www.whitehouse.gov/articles/2026/03/white-house-unveils-president-trumps-cyber-strategy-for-america/

https://www.whitehouse.gov/wp-content/uploads/2026/03/President-Trumps-Cyber-Strategy-for-America.pdf

 

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Combating Cybercrime, Fraud, And Predatory Schemes Against American Citizens

 

March 6, 2026: 91 Fed. Reg. 12051: The President issued EO 14390 Combating Cybercrime, Fraud, And Predatory Schemes Against American Citizens, in which the policy of the U.S. is to protect Americans from, and harden our financial and digital systems against, these threats. The United States shall counter attacks on Americans with a commensurate response that includes law enforcement, diplomacy, and potential offensive actions. It is further the policy of the United States to provide support to victims of these crimes, expand public alerts, and prioritize protection for those most at risk to end the exploitation and victimization of Americans.

 

The EO directed the Secretary of State, the Secretary of the Treasury, the Secretary of War, the Attorney General, and the Secretary of Homeland Security, in consultation with the Office of the National Cyber Director, and in coordination with the Assistant to the President and Homeland Security Advisor (APHSA) to:

• Review the relevant operational, technical, diplomatic, and regulatory frameworks in place to determine how each can be improved to best combat Transnational Crime Organizations (TCOs) engaged in cyber-enabled crime and similar predatory schemes against Americans;
• Submit to the President, through the APHSA, an action plan that identifies the TCOs responsible for scam centers and cybercrime and proposes solutions to prevent, disrupt, investigate, and dismantle these TCOs;
• Submit a recommendation to the President, through the APHSA, regarding the establishment of a Victims Restoration Program designed to provide, to the greatest extent authorized by law and in consideration of the Department of Justice’s goal of serving all victims of crime, restoration or remission to victims of cyber-enabled fraud schemes from funds clawed back, forfeited, or seized from the TCOs that perpetrate such schemes; and
• Engage with foreign governments to demand enforcement actions against TCOs operating within their borders and greater cooperation with United States law enforcement.

 

https://www.whitehouse.gov/presidential-actions/2026/03/combating-cybercrime-fraud-and-predatory-schemes-against-american-citizens/

 

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Adjusting Certain Delegations Under The Defense Production Act

 

March 13, 2026: 91 Fed. Reg. 14391: The President issued EO 14391 amending EO 13603 dated March 16, 2012(National Defense Resources Preparedness).  Executive Order 13603 delegates certain authorities of the President under the Defense Production Act (50 U.S.C. 4501 et seq.), to specified executive department and agency (agency) heads.  This order also clarifies section 2(a) of Executive Order 14156 of January 20, 2025 (Declaring a National Energy Emergency).

 

EO 14391 amended Section 203 of Executive Order 13603 by striking the phrase “Secretary of Commerce” and inserting, in lieu thereof, “Secretary of Commerce and the Secretary of Energy, each of whom may exercise such delegated authority independently of the other”.

 

https://www.whitehouse.gov/presidential-actions/2026/03/adjusting-certain-delegations-under-the-defense-production-act/

 

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Fact Sheet: The President Strengthens U.S.-Japan Alliance for the Benefit of All Americans – The White House

 

March 19, 2026: The Administration released a fact sheet announcing new initiatives to strengthen the U.S.-Japan Alliance, enhance economic security, and bolster deterrence to advance a free and open Indo-Pacific.

 

Of note, the United States welcomed Japan’s commitment to rapidly strengthen its own defense capabilities, increase its defense budget, and continue partnering with U.S. forces in Japan and the region.

• The United States and Japan affirmed their commitment to deploying advanced capabilities in Japan to enable a strong denial defense posture.  This year, the two sides will maintain close coordination, building on the successful 2025 deployment of the U.S. Typhon missile system to mainland Japan.
• Following the bilateral feasibility study for AIM-120 Advanced Medium-Range Air-to-Air Missile (AMRAAM) co-production, the two countries will scope Japan’s future role in increased AMRAAM production capacity.
• In support of missile defense cooperation, the two sides will rapidly increase by fourfold the production of Standard Missile 3 Block IIA missiles in Japan.
• The United States welcomed Japan’s commitment to develop a secure and sovereign cloud platform for government data to enhance bilateral information sharing, planning, and coordination.

 

https://www.whitehouse.gov/fact-sheets/2026/03/fact-sheet-president-donald-j-trump-strengthens-u-s-japan-alliance-for-the-benefit-of-all-americans/

 

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Department of State

 

Defense Trade Advisory Group; Notice of Membership

 

March 19, 2026: The U.S. Department of State’s Bureau of Political-Military Affairs (the Bureau) is accepting membership applications for the Defense Trade Advisory Group (DTAG). The Bureau is interested in applications from subject matter experts, including from the United States defense industry, relevant trade and labor associations, and academic and foundation personnel.

 

DTAG members’ responsibilities include:

• Making recommendations in accordance with the DTAG Charter and the FACA.
• Making policy and technical recommendations within the scope of the U.S. export controls as set forth in the AECA, the ITAR, and appropriate directives.

 

Please note that DTAG members may not be reimbursed for travel, per diem, and other expenses incurred in connection with their duties as DTAG members.

 

How to apply: Applications in response to this notice must contain the following information: (1) Name of applicant; (2) affirmation of U.S. citizenship; (3) organizational affiliation and title, as appropriate; (4) mailing address; (5) work telephone number; (6) email address; (7) resume; and (8) summary of qualifications for DTAG membership.

 

This information may be provided via two methods:

• Emailed to the following address: DTAG@State.Gov. In the subject field, please write, “ DTAG Membership Application. ”
• Send hardcopy to the following address: Paula Harrison, PM/DDTC, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political-Military Affairs, U.S. Department of State, Washington, DC 20522-0112. If sent via regular mail, we recommend you call Ms. Harrison (202-663-3310) to confirm she has received your package.

 

All applications must be postmarked no later than 15 days after the publication date of this notice.

 

https://www.federalregister.gov/documents/2026/03/19/2026-05408/defense-trade-advisory-group-notice-of-membership

 

 

Fiscal Year 2025 U.S. Arms Transfers and Defense Trade

 

March 16, 2026: The U.S. Department of State released the Fiscal Year 2025 U.S. Arms Transfers and Defense Trade

 

Total Sales:

In FY 2025 the number for total sales, both government to government Foreign Military Sales, and exports licensed via Direct Commercial Sales was $331.18 billion. This represents a 3.92 percent increase over the FY 2024 figure of $318.70 billion.

 

Foreign Military Sales:

In FY 2025 the total value of transferred defense articles and services and security cooperation activities conducted under the Foreign Military Sales system was $104.38 billion. This represents an 11.47 percent decrease, down from $117.85 billion in FY 2024. In FY 2025, the Department of State oversaw 16,098 FMS cases with an open case value of over $934 billion.

 

Direct Commercial Sales:

The total authorized value for privately contracted Direct Commercial Sales (DCS) authorizations for FY 2025 was $226.8 billion, which includes the value of hardware, services, and technical data authorized for exports, temporary imports, reexports, retransfers, and brokering. This represents a 12.9 percent increase, up from $200.8 billion in FY 2024.

 

https://www.state.gov/releases/bureau-of-political-military-affairs/2026/03/fiscal-year-2025-u-s-arms-transfers-and-defense-trade/

 

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Directorate of Defense Trade Controls (DDTC)

 

Registration Application Enhancement Release

 

March 26, 2026: DDTC announced that beginning March 27, 2026, email notifications will be sent the day after a registration expires to the Senior Officer, Points of Contact, and Corporate Administrators associated with the registration. This notification is intended to provide timely prompt action for renewal, minimize the duration of any registration lapses, avoid lapse-related fees, and help organizations maintain ITAR compliance.

 

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

 

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DDTC Name And Address Changes Posted To Website

 

March 1 through March 31, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at    

https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&sys_id=bd72ca0adbf8d30044f9ff621f961981:

 

• Curtiss-Wright foreign subsidiary Ultra Nuclear Limited changed its name to Curtiss-Wright Wimborne Limited due to corporate restructuring.
• Mitsubishi Space Software Co., Ltd. changed its name to Mitsubishi Electric Software Corporation due to corporate restructuring.
• Muirhead Avionics UK changed its address from 3 The Square, Heathrow, UB2 5NH, South, United Kingdom to Muirhead Avionics UK, Quadrant House, 50 Heron Drive, Langley, Berkshire, SL3 8XP, United Kingdom.
• Neotek changed its name to RTsys Monitoring Solutions due to corporate rebranding.
• Schleifring North America, LLC’s subsidiary Electro-Miniatures Corp. changed its address from 68 W. Commercial Ave., Moonachie, NJ 07074 to 80 Hancock Street, Lodi, NJ 07644.
• TUSAS Motor Sanayii A.S. changed its address from Muttalip Mevkii Mrk Pk 610, Eskisehir 26003, Turkey to Esentepe Mahallesi Cevre Yolu Bulvari, No:356, Tepebasi, Eskisehir 26210, Turkey.
• GE Aviation Systems Australia Pty Ltd changed its address from 34 Boronia Road, Brisbane Airport 4008, Australia to 34 Boronia Road, Brisbane Airport, Brisbane 4008, Queensland, Australia.
• DSV Air & Sea, Inc. Entities Names and Locations due to corporate restructuring
  • From: Avenida Presidente Riesco nùmero 5335 Oficinas 504 y 505, L 7561127 Santiago Chile

To: DSV Air & Sea S.A. Avenida Andres Bello 2687 Office 801 Building Del Pacifico, Las Condes, Santiago, Chile 755066 Santiago Chile

• From: Schenker d.o.o. Ulica Franje Lucica 32 10090 Zagreb Croatia

To: DSV Hrvatska d.o.o. Zelena aleja 55 10410 Velika Gorica Croatia; and

DSV Road Croatia d.o.o. Ulica Franje Lucica 32 10090 Zagreb Croatia

• From: AS Schenker Pärnu mnt 535 31136 Chihuahua 76404 Sakuv

To: DSV Air & Sea AS Pärnu mnt. 535 76401 Saku Vald Estonia; and

DSV Road AS Pärnu mnt 535 76404 Saku vald, Estonia Estonia

• From: Schenker A.E. Thesi Gropa Kyrillos 19300 Asproryrgos Greece

To: DSV Air & Sea Single Member S.A. 100 Alimou Ave. 164 52 Argyroupolis (Athens) Greece;

DSV Road Single Member S.A. 100, Alimou AV 164 52 Argyroupolis Athens Greece; and DSV Road Greece Thesi Gropa Kyrillosv 19300 Asproeyrgos Greece

• From: SIA Schenker Katlakalna iela 11c 1073 Riga Latvia

To: SIA DSV Latvia Krustpils street 31 1073 Riga Latvia

• From: Schenker Philippines Inc KM. 19, WSR, Sabrina Compound, Brgy. Marcelo Green Village 1700 Paranaque City Philippines
• To: DSV Air & Sea Inc. 6th Flr. West Tower 8912 Asean Avenue Bldg. Cor. N. Abueva 1700 Paranaque City Philippines;

DSV Contract Logistics, Inc. KM19 Sabrina Compound West Service Road Marcelo Green Village 1700 Paranaque City Philippines;

DSV Global Solutions Inc People’s Technology Complex, SEZ, Brgy Maduya, Carmona 4116 Cavite Philippines;

DSV Ecozone Logistics, Inc., Standard Factory Building 3, Laguna Technopark Brgy. Mamplasan 4024 Biñan Laguna Philippines; and

DSV Road KM19 West Service Rd., Sabrina Compound Marcelo Green 1700 Paranaque City Philippines

• From: Schenker Logistics AB Hangarvägen 1 438 70 Landvetter Sweden;

Schenker AB Österleden 201 261 51 Landskrona Sweden; and

Schenker Logistics AB Hangarvägen 1 438 70 Landvetter Sweden

To: DSV Air & Sea AB Österleden 201 261 51 Landskrona Sweden;

DSV Road AB Moelndalsvaegen 83 41285 Gothenburg Sweden; and

DSV Contract Logistics AB Österleden 201 261 51 Landskrona Sweden

• From: Schenker Schweiz AG Rautistr. 77 8048 Zuerich Switzerland

To: DSV Air & Sea AG St. Jakobs-Strasse 220 4052 Basel Switzerland; and

DSV Logistics S.A. Via Passeggiata 24 6828 Balerna, Switerland

• From: Schenker Saudi Arabia LLC Riyadh Avenue Mall, Avenue 2, 3rd Floor Hai Ul Murabba Riyad 51615 Riyadh Saudi Arabia

To: DSV Air and Sea for Logistics Services Company Blue Tower – 5th Floor (B-Wing), King Faisal Road – 13th street, P.O. Box 1499 31952 Al-Khobar Saudi Arabia; and

DSV Contract Logistics for Logistics Services Company Sinaeyat Slay – Istanbul Street 11464 Riyadh Saudi Arabia

• From: UAB “Schenker” Savanoriu ave. 5 03116 Vilnius Lithuania

To: DSV Lithuania UAB Stasylu 21 02244 Vilnius Lithuania

• From: Schenker (NZ) Limited 50 Richard Pearse Drive, Airport Oaks 2022 Auckland New Zealand
  To: DSV Air & Sea Limited 19 Landing Drive, Auckland International Airport 2022 Auckland New Zealand
• From: Schenker Logistics – L.L.C – S.P.C Hamdan bin Mohammed Street Abu Dhabi United Arab Emirates

To: DSV Contract Logistics PJSC PO Box 93971, Street No. 10, Sector M19, Mussafah Abu Dhabi United Arab Emirates

• From: Schenker of Canada Ltd. L4V 1W5 Mississauga, Ontario 5935 Airport Road, 10th floor Canada

To: DSV Air & Sea Inc. 2200 Yokon Court Ontario L9E 1N5 Milton Canada;
DSV Road Inc 2200 Yokon Court Ontario L9E 1N5 Milton Canada; and
DSV Contract Logistics Inc. 2200 Yokon Court Ontario L9E 1N5 Milton Canada

• From: Schenker France SAS Z.I. Nord 85600 Montaigu France

To: DSV Air & Sea SAS 9-23 Chemin des Petits Marais 92230 Gennevilliers France;

DSV Road SAS 19-23 Chemin des Petits Marais 92230 Gennevilliers Cedex France; and

DSV Contract Logistics SAS 33, Rue de Reckem 59960 Neuville en Ferrain France

• From: Schenker Vietnam Co. Ltd 14th Floors-Tower A, 285 Cach Mang Thang 8 Hoa Hung Ward Ho Chi Minh City Viet Nam

To: DSV Air & Sea Company Limited 3B FLOOR REPUBLIC PLAZA BUILDING, 18E CONG HOA ST., WARD 4, TAN BINH DISTRICT Ho Chi Minh City Vietnam

• From: Schenker Italiana S.p.A. (à DSV Road Spa) Via Fratelli Bandiera 29 20068 Peschiera Borromeo (MI) Italy

To: DSV SpA (à DSV Air&Sea Spa) Via Dante Alighieri 134 20096 Pioltello Italy; and
DSV Solutions S.R.L (à DSV Contract Logistics Srl.) Via Dante Alighieri 134, Frazione Limito 20096 Pioltello Italy

• Luerssen Australia Pty Ltd changed its ownership and name as follows:
  • Previous Owner Name and Address:

NVL B.V. Co. ZKG Zum Alten Speicher 11 28759 Bremen, Germany

New Owner Name and Address:
Civmec Limited (CVL) 16 Nautical Drive, Henderson, WA 6166  Australia

• Entity Named on Existing Agreement:

Luerssen Australia Pty Ltd. (Luerssen) 16 Nautical Drive, Henderson, WA 6166  Australia

New Entity:

Civmec Defence Industries (CDI) 16 Nautical Drive, Henderson, WA 6166 Australia

• L3Harris Interstate Electronics Corporation changed its address from 602 E. Vermont Avenue, Anaheim, California 92805 to 22745 Savi Ranch Parkway, Yorba Linda, California 92887
• General Electric International Inc. changed its name to Arcam AB due to corporate restructuring.
• LIG Nex1, Ltd. changed its name to LIG Defense & Aerospace Co., Ltd. due to corporate rebranding.

 

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DDTC Frequently Asked Questions (FAQs)

 

Q: How can a user become a Corporate Administrator (CA) in DECCS?

A: (Updated 3/2/2026) A user can become a Corporate Administrator (CA) in DECCS through the following methods:

 

1. Designation by an Existing CA

An existing Corporate Administrator can designate any user as a CA via the DECCS User Management (UM) application.

 

2. Senior Officer (SO) Request

If you are a Senior Officer, you can use last year’s signed registration notification letter from DDTC in place of a CA Request letter, provided the letter includes:

• Company name
• Registration code
• Your name as the Senior Officer

 

3. Submission of a CA Request Letter

Send a CA Request letter on company letterhead in PDF format with the following details:

• Date
• Company name and mailing address
• DDTC registration code
• Brief description of the request (e.g., Request for John Smith to be designated as a CA)
• Title and contact information of the requested CA (name, phone number, and email used for DECCS enrollment)
• Senior Officer (SO)/Empowered Official (EO) signature (handwritten or cryptographic-based; font-based signatures are not allowed) in addition to their title and contact information.

 

Important Notes

• Ensure your company has no new registrations in progress before submitting the CA Request letter. Any renewal registration will fail if new registrations are active.
• It is recommended to have multiple Corporate Administrators to avoid disruptions due to absences or departures.

 

Submission Methods

Send the CA Request letter to DDTC Help Desk using one of the following methods:

• Update an Existing Support Case: Log into DECCS, go to My Support Cases, click Needs Attention, locate the case, and upload the CA Request letter.
• Create a New Support Case: Log into DECCS, go to My Support Cases, and click Create a New Support Case. Refer to How do I submit a Support Case request?

 

Processing Time

Once the request is received, allow 1–2 business days for completion.

 

 

Q: How do I add a new Corporate Administrator (CA) in DECCS?

 

A: To add a new Corporate Administrator (CA), you must already be a CA yourself. Follow these steps to designate another user as a CA:

1. Log in to DECCS and click the Applications menu in the top navigation bar.

1. Select the User Management option.

1. In the Company Users section, find the user you want to make a CA.

1. Check the CA checkbox next to the user’s email address.

1. Once the change is applied, a green banner will appear at the top of the screen with the message: “User Updated Successfully.”

The user will now have Corporate Administrator privileges and can manage user accounts and access within your organization.

 

Q: How do I switch my DECCS profile to a new email address?

 

A: To switch your DECCS profile to a new email address, you’ll need to create a new DECCS account using your new email and have your Corporate Administrator (CA) connect it to your company’s profile.

 

You may need to do this if you’ve changed companies, updated your organization’s email domain, or no longer have access to your old email account.

 

Steps:

• Create your new DECCS account – Go to https://deccs.pmddtc.state.gov/deccs and click Enroll.

• • Register using your new email address and complete the Okta verification process.

• Request company access- If you’re a Corporate Administrator (CA), log into DECCS with your old account and invite your new email under Applications → User Management → Add User.

• • If you’re not a CA, ask your CA to send this invitation.

• Accept the invitation – Log into DECCS with your new account and accept the company invitation under User Management.

• Update roles and permissions (CA required) – Your CA must assign your Registration and Licensing roles to the new account and mark it as a Corporate Administrator, if applicable.

• Remove your old account – Once the new account is active, your CA should remove your old email from the company user list.

• Clean up – Delete the old account from your Okta Verify app.
  • Submit a Support Case (from your old account email) requesting deactivation of the old DECCS account. Include the old email address in your message.

 

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REMINDER: It’s Time For Annual Sales Report Filings To Be Made With DDTC For Manufacturing License Agreements And Warehousing Distribution Agreements For Sales And Transfers That Occurred In 2025

 

 

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Bureau of Political-Military Affairs – Foreign Military Arms Sales

 

BPMA Notified Congress of Potential FMS Sales to the following Countries:

 

Details regarding each case can be found at the links below.

 

Israel

Sweden

United Arab Emirates

Jordan

Kuwait

United Kingdom

Republic of Korea

Japan

Belgium

 

https://www.state.gov/israel-munitions-and-munitions-support/

 

https://www.state.gov/releases/bureau-of-political-military-affairs/2026/03/sweden-m142-high-mobility-artillery-rocket-systems/

 

https://www.state.gov/united-arab-emirates-advanced-medium-range-air-to-air-missiles-amraams/

 

https://www.state.gov/releases/bureau-of-political-military-affairs/2026/03/united-arab-emirates-f-16-munitions-and-upgrades/

 

https://www.state.gov/united-arab-emirates-long-range-discrimination-radar-with-terminal-high-altitude-area-defense-integration/

 

https://www.state.gov/government-of-jordan-aircraft-repair-return-and-spares/

 

https://www.state.gov/releases/bureau-of-political-military-affairs/2026/03/kuwait-lower-tier-air-and-missile-defense-sensor-radars/

 

https://www.state.gov/releases/bureau-of-political-military-affairs/2026/03/united-arab-emirates-fixed-site-low-slow-small-unmanned-aircraft-integrated-defeat-system/

 

https://www.state.gov/releases/bureau-of-political-military-affairs/2026/03/united-kingdom-submarine-combat-and-weapon-systems-technical-support-u-s-and-uk-embedded-personnel-and-associated-training/

 

https://www.state.gov/republic-of-korea-arc-210-rt-2036c-secure-radios-and-ky-100m-communication-security-devices/

 

 

https://www.state.gov/japan-hyper-velocity-gliding-projectile-hvgp-program-support/

 

https://www.state.gov/belgium-communications-equipment/

 

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

 

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

March 4, 2026: BIS updated its guidance regarding the availability of License Exception SCP for exports and reexports of U.S.-origin gas and other petroleum products to eligible Cuban private sector entities and to individual Cuban consumers. Certain transactions that meet SCP terms may be authorized without a license, and applications that otherwise qualify will be returned without action with instruction to use the exception. Exporters are responsible for ensuring that all SCP conditions are met and should carefully review § 740.21 before proceeding.

 

https://www.bis.gov/

 

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Suspension Related to Cuban-Owned Banks

 

March 4, 2026: BIS suspended the availability of License Exception Support for the Cuban People (SCP) under § 740.21(b)(1) for any export, reexport, or transfer involving the deposit of foreign funds into a Cuban‑owned bank. BIS determined that such transactions present an unacceptable risk of primarily benefiting the Cuban government and its military or intelligence services. This suspension does not apply to transactions that avoid Cuban banks, such as those routed through third‑country financial institutions, nor to shipments already en route by March 4, 2026, if completed by April 3, 2026. Exporters remain responsible for ensuring full compliance with § 740.21 and all SCP conditions before proceeding.

BIS updated its Cuba Export Controls Country Guidance by adding Suspension Related to Cuban-Owned Banks.

 

BIS determination to suspend the availability of License Exception SCP under § 740.21(b)(1) for any export, reexport, or transfer (in-country) involving a Cuban owned bank

• There are longstanding and documented issues of diversion and fees associated with Cuban banks. The Cuban banks form the basis of the regime’s financial infrastructure, and many are designated on the Cuba Restricted List due to being under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel. It is well established that it is not the policy of the United States to permit transactions that significantly benefit the Cuban government or its designated military institutions.
• Accordingly, transactions involving the deposit of foreign funds into Cuban government banks, including those on the Cuba Restricted List or associated with the military and intelligence services, may serve to primarily generate revenue for or contribute to the operation of the Cuban state.
• Taking these considerations above into account and the need to protect U.S. national security and foreign policy interests, BIS has determined that there is an unacceptable risk that transactions involving Cuban banks may primarily benefit the Cuban government, contrary to the purpose of License Exception SCP of supporting independent economic activity in Cuba.
• Pursuant to § 740.2(b) of the EAR, which specifies that “all License Exceptions are subject to revision, suspension, or revocation, in whole or in part, without notice to protect U.S. national security or foreign policy interests,” BIS is informing all exporters, reexporters, and transferors that License Exception Support for the Cuban People (SCP), § 740.21(b)(1), is suspended as of March 4, 2026, for any export, reexport, or transfer (in-country) involving the deposit of foreign funds into a Cuban owned bank.
• This BIS suspension does not apply to exports, reexports, or transfers (in-country) that do not involve Cuban banks, e.g., involving third country banks or other financial payment systems that do not involve the deposit of foreign funds into Cuban banks. This BIS suspension also does not apply to any export or reexport that was en route aboard a carrier to a port of export or reexport on March 4, 2026, pursuant to actual orders for export or reexport to Cuba, provided that the export or reexport is completed no later than April 3, 2026.

Updated Guidance Regarding Available EAR License Exceptions for Exports of Gas and Petroleum Products to Cuban Private Sector Entities and Activities

• The Bureau of Industry and Security (BIS) has been receiving questions from potential exporters on the EAR requirements and potential EAR authorizations that may be available to authorize exports of gas and petroleum products and reexports of U.S.-origin gas and petroleum products for private sector use, including for addressing humanitarian needs in Cuba.
• In general, a license is required to export and reexport gas and other petroleum products that are subject to the EAR to Cuba pursuant to § 746.2(a). However, as with any export or reexport that is subject to a license requirement, the exporter or reexporter should first evaluate whether a license exception is available to authorize the export or reexport.
• In particular, exporters and reexporters of gas and petroleum products subject to the EAR to the Cuban private sector should review the general restrictions under § 740.2 and § 740.21. As explained below, gas and other petroleum products exported and reexported to Cuban private sector entities or individuals for personal use (or their fa may be authorized under License Exception SCP.
• Exporters and reexporters are advised that if a license application is submitted to BIS that otherwise meets the terms and conditions of License Exception SCP, those applications will be returned without action (RWA’d) by BIS with a direction to the applicant to export or reexport the items pursuant to License Exception SCP.
• BIS provides the following FAQ to further assist public understanding:

Q.1: Would License Exception Support for the Cuban People (SCP) (§ 740.21 of the EAR) allow an exporter or reexporter to export or reexport gas and other petroleum products to Cuban private sector entities for private sector use, or directly to individual Cubans for their personal or family use?
A.1: Yes, provided that all the applicable terms and conditions of License Exception SCP are met. Specifically, there are two authorizing paragraphs under License Exception SCP under paragraph (b) (Improving living conditions and supporting independent economic activity), which may be available to authorize these types of exports and reexports of gas and other petroleum products to Cuba. License Exception SCP provides a general authorization for exports under certain applicable conditions, as explained below, and does not contain any specific limitations on applicability based on quantity or value of the items, or exporter or reexporter.

 

• 740.21(b)(1). Exports to private sector for private sector use. If the gas and other petroleum products are being exported (or reexported) for use by the Cuban private sector for private sector use, then paragraph (b)(1) of License Exception SCP, which authorizes items for use by the Cuban private sector for private sector economic activities, may be available to authorize these types of exports and reexports. To qualify, exports must be both (1) for use by the Cuban private sector, and (2) for private sector economic activities, including those addressing humanitarian needs in Cuba. Per § 740.21(b)(1)(i) and (ii), License Exception SCP does not apply to any transactions, whether to Cuban private sector entities or otherwise, which primarily generate revenue for the state; or contribute to the operation of the state, including through the construction or renovation of state-owned buildings.

 

• 740.21(b)(2). Exports sold directly to individuals in Cuba for their personal use.

If the gas and other petroleum products are sold directly to individuals in Cuba for their personal use, then paragraph (b)(2) of SCP, which authorizes items sold directly to individuals in Cuba for their personal use (or their immediate family’s personal use), may be available to authorize exports and reexports of such products.

 

Paragraph (b)(2) does not require the products to be exported or reexported directly to the individuals; however, the products must ultimately be destined for these eligible end users (and/or their families) for their personal use.

 

This authorization applies only if the gas or other petroleum products are sold directly to individual Cubans for their personal use or the use of their immediate family. It does not apply if any of the products are sold or transferred to proscribed persons or entities in Cuba, including employees of the Ministry of Defense or Ministry of the Interior, senior officials of certain Cuban government organizations, labor unions, and other Cuban government affiliated organizations, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 CFR 515.209.

 

Note: Exporters and reexporters are responsible for ensuring that all of the applicable terms and conditions of License Exception SCP are met. Please review EAR § 740.21 — License Exception Support for Cuban People (SCP) — carefully to ensure that your transaction meets all the criteria for use of the license exception. Exporters who are unable to determine if they can satisfy all terms and conditions of License Exception SCP should submit an application for an individual validated license.

https://www.bis.gov/media/documents/030426-scp-gas-petroleum-bank-faq.pdf

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

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Department of Commerce – International Trade Administration       

Department of Commerce Announces New American AI Exports Program Phase

March 16, 2026: The U.S. Department of Commerce announced further implementation of the American AI Exports Program with a Call for Proposals from U.S. industry-led consortia to export full-stack AI technology packages. Under President Donald J. Trump’s AI Action Plan and export directives, the Department of Commerce is implementing a full-stack AI export package promotion program to advance America’s AI leadership globally.

Beginning April 1, 2026, and for 90 days, industry-led consortia may submit proposals for full-stack AI export packages, including AI optimized computer hardware, data center storage, models, cybersecurity measures, and applications for various sectors.

The call for proposals includes two types of industry-led consortia: pre-set consortium and on-demand consortium. Pre-set consortia demonstrate capability across all layers of the AI technology stack and maintain global offerings ready for deployment on an ongoing basis. These will become the U.S. Government’s offerings to allies and partners around the world. On-demand consortia are formed by industry in response to a specific opportunity identified by the Program and need only cover the stack layers required for the specific deal. These on-demand consortia are formed as “custom-made” options for specific opportunities.

Both pre-set and on-demand consortia are designated through a single selection process: the Secretary of Commerce, in consultation with the Secretary of State, the Secretary of War, the Secretary of Energy, and the Director of the Office of Science and Technology Policy, selects proposals for inclusion in the Program. Once approved, full-stack AI technology can be available to trusted foreign buyers of U.S. technology.

Under the Program, approved consortia may also receive support from across the U.S. Government, including priority for export control license reviews, prioritized access to U.S federal credit programs, government-to-government engagement via direct advocacy, and dedicated interagency coordination.

Full program information and proposal processes will be published in a forthcoming Federal Register notice.

https://www.trade.gov/press-release/department-commerce-announces-american-ai-exports-program-implementation

 

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Federal Communications Commission

 

On March 23, 2026, the Federal Communications Commission updated its Covered List to include all consumer-grade routers produced in foreign countries. Routers are the boxes in every home that connect computers, phones, and smart devices to the internet. This followed a determination by a White House-convened Executive Branch interagency body with appropriate national security expertise that such routers “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.

 

See our articles on this topic on FD Associates’ LinkedIn page.

 

https://docs.fcc.gov/public/attachments/DOC-420034A1.pdf

LATEST SANCTIONS FINES & PENALTIES

 

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

 

Fines and Penalties

 

February 25, 2026: Gerald Eddie Brown, Jr., 65, a former U.S. Air Force officer and pilot, was arrested in Jeffersonville, Indiana, and charged by criminal complaint for providing, and conspiring to provide, unauthorized defense services to Chinese military pilots in violation of the Arms Export Control Act.

 

Since August 2023, Brown willfully conspired with foreign nationals to provide combat aircraft training to pilots in the Chinese Air Force, known as the People’s Liberation Army Air Force (PLAAF). This training was a defense service under the International Traffic in Arms Regulations (ITAR) and Brown lacked the required license from the State Department’s Directorate of Defense Trade Controls to provide that training to foreign persons or foreign military units.

 

Brown served for more than 24 years in the U.S. Air Force and retired in 1996 with the rank of Major. During his military career, Brown commanded sensitive units with responsibility for nuclear weapons delivery systems, led combat missions, and served as a fighter pilot instructor and simulator instructor on a variety of fighter and attack aircraft, including the F-4 “Phantom II,” F-15 “Eagle,” F-16 “Fighting Falcon,” and the A-10 “Thunderbolt II” (Warthog). Brown then served as a commercial cargo pilot and, most recently, as a contract simulator instructor for two different U.S. defense contractors training U.S. military pilots on flying the A-10 and the F-35 Lightning II Joint Strike Fighter.

 

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

 

Throughout these communications, Brown consistently stated his intent to train PRC military pilots in combat aircraft operations. In the resumé he prepared for his application, Brown wrote his “objective” as “Instructor Fighter Pilot.” A co-conspirator told Brown that he hoped Brown would be assigned to “my base, but otherwise you’ll go where is the local equivalent as the [U.S. Air Force] Weapon School.” Later, Brown stated to a co-conspirator that, upon his arrival in China, “Now…. I have the chance to fly and instruct fighter pilots again!”

 

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

 

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March 17, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that TradeStation Securities, Inc. (“TradeStation”) has agreed to pay $1,110,661 to settle its potential civil liability for 481 apparent violations of OFAC sanctions programs arising from TradeStation’s provision of brokerage and investment services to persons in Iran, Syria, and Crimea, between June 2021 and June 2022. The settlement amount reflects OFAC’s determination that TradeStation’s conduct was non-egregious and was voluntarily self-disclosed.

 

TradeStation implemented compliance systems to comply with U.S. sanctions.  The compliance systems included:

• Background checks of prospective customers that include screening against OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) and rescreenings of its existing customers against the SDN List on a daily basis. Each customer’s primary residence is screened to ensure they do not reside in a sanctioned jurisdiction.
• IP Geo-blocking technology to verify the location of its users while they utilized TradeStation’s web-based and mobile platforms to prevent access to TradeStation’s platforms from sanctioned jurisdictions. A key element of this system was a firewall designed to deny users with IP addresses associated with sanctioned jurisdictions from accessing TradeStation’s systems (the “first-tier geo-blocking”). TradeStation ran a separate third-party IP address verification tool that acted as a second layer of defense by authenticating a user’s IP address upon login to TradeStation’s web-based and mobile platforms and denied access based on location (the “second-tier geo-blocking”).
• Subscription to a third-party service that alerted TradeStation’s sanctions compliance personnel to access attempts that had been prevented by the geo-blocking controls. These notifications, which were delivered daily, documented efforts by TradeStation clients to access its platforms in jurisdictions subject to OFAC sanctions and other certain jurisdictions.

 

The violations are the result of:

• Failures In Tradestation’s IP Geo-Blocking Measures
  • TradeStation designed and implemented proprietary software to improve the functionality and the overall user experience of TradeStation’s mobile platform. This new software, however, inadvertently rendered TradeStation’s second-tier geo-blocking ineffective for users of its mobile platform. Instead of identifying and screening the user’s IP address at the time of an attempted login to prevent users from sanctioned jurisdictions from trading, the second-tier geo-blocking protocol detected the IP address of the U.S.-located server from which TradeStation’s new mobile platform software ran. This prevented the second-tier geo-blocking controls from functioning as designed, rendering them incapable of identifying users in Iran, Syria, and Crimea.
  • Additionally, one of TradeStation’s employees inadvertently failed to reenable the first-tier geo-blocking control after disabling it to install a software update from TradeStation’s cloud services provider. This left TradeStation’s first-tier geo-blocking controls effectively disabled, and they remained so for nearly 12 months. During this period, TradeStation was not restricting access to its mobile platform by users with IP addresses associated with sanctioned jurisdictions (although sanctioned users attempting to access the web-based platform would have been blocked by the second-tier geo-blocking controls). Consequently, users located in Iran, Syria, and Crimea were able to access TradeStation’s mobile platform and execute 481 trades during this time
• Failures To Test Or Validate Sanction Compliance Systems
  • TradeStation developed an automated testing tool for its on-premises servers that would simulate access attempts by users with IP addresses associated with sanctioned jurisdictions. However, TradeStation later discovered that its third-party internet service and cloud providers were blocking these test access attempts before they could reach TradeStation’s systems. TradeStation discontinued the use of this tool without replacing it, and, as a result, TradeStation had no effective testing mechanism—neither related to its on-premises servers nor its mobile platform—in place to ensure that its IP geo-blocking controls were functioning as intended at the time the 481 apparent violations occurred.
  • TradeStation maintained a third-party service that alerted sanctions compliance personnel of access attempts from sanctioned jurisdictions. On September 21, 2021, a TradeStation-affiliated employee received an email from the third-party provider of its daily notifications that TradeStation’s subscription would be expiring. This employee failed to renew the subscription and did not notify others in TradeStation’s sanctions compliance department about the expiration of the daily notifications. For a period of over eight months, TradeStation’s sanctions compliance personnel failed to address the absence of its once-daily OFAC alerts and did not consider or act on what the lack of notifications might have signaled about TradeStation’s sanctions compliance program.

 

Key Take Aways:

OFAC made the point to highlight:

• The importance of regular testing and auditing to ensure sanction compliance controls are effectively mitigating risk and preventing violations. The most well-designed sanctions compliance program can be rendered wholly ineffectual by human and technical errors. Comprehensive, independent, and objective testing and auditing can help catch problems early and provide opportunities for remediation, thereby limiting risk of violating sanctions.
• Regular testing and auditing also provide opportunities for evaluating sources of sanctions risk and ensuring that appropriate controls are in place to address them. Controls should be well designed to address particular sanctions risks, including those presented by particular technology offerings. These controls may include appropriately calibrated screening protocols, geo-blocking controls, and Virtual Private Network detection software. They may also include controls to validate proper system operation and execution following any outage, including due to planned maintenance or upgrade.
• Companies should not treat testing and auditing as box-checking exercise. Sanctions risks are dynamic and may fluctuate as prohibitions change or as businesses evolve. While technological solutions are often a critical part of an effective sanctions compliance program, firms should ensure they are not overly relying on a patchwork of software or taking a “set it and forget it” approach to compliance.

 

https://ofac.treasury.gov/recent-actions/20260317

https://ofac.treasury.gov/media/935351/download?inline

 

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March 19, 2026: The Department of Justice charged Yih-Shyan “Wally” Liaw, Ruei-Tsang “Steven” Chang, and Ting-Wei “Willy” Sun, for allegedly conspiring to divert high-performance computer servers assembled in the United States and integrating sophisticated U.S. artificial intelligence technology manufactured by Nvidia Corporation to China, in violation of U.S. export controls laws.  Liaw, a U.S. citizen, and Sun, a citizen of Taiwan, were arrested and will be presented in the Northern District of California. Chang, a citizen of Taiwan, remains a fugitive.

 

Liaw is a co-founder, board member, and Senior Vice President of Business Development of Super Micro Computer, a publicly traded U.S.-based manufacturer that designs and builds high-performance computer servers for artificial intelligence and cloud computing applications, including servers that integrate Nvidia artificial intelligence graphics processing units (GPUs).  Chang is a general manager in the U.S. Manufacturer’s Taiwan office.  Sun is a third-party broker and “fixer” who has worked with Liaw, Chang, and others to divert U.S.-export controlled technology to China.  Together, the defendants and others conspired to systematically divert the U.S. Manufacturer’s servers with certain GPUs to China without a license to do so from the U.S. Department of Commerce.

 

The scheme operated as follows. Liaw and Chang, who worked closely with third-party brokers with customers based in China, directed certain executives of a company based in Southeast Asia (“Company-1”) to place purchase orders with the U.S. Manufacturer for servers with certain GPUs, purportedly for Company-1.  Those servers were often assembled in the United States and shipped to the U.S. Manufacturer’s facilities in Taiwan, then delivered to Company-1 elsewhere in Southeast Asia. Company-1, in consultation with the defendants, then used a shipping and logistics company to repackage the U.S. Manufacturer’s servers and place them in unmarked boxes to conceal their content prior to shipping them to their final destinations in China.  To ensure that these server allocations were approved internally at the U.S. Manufacturer, the defendants and executives at Company-1 prepared false documents and records, and transmitted false communications, purporting to show that Company-1 was the end user of the servers.

 

The defendants and their co-conspirators took extensive measures to conceal their scheme.  As just one example, to deceive the U.S. Manufacturer’s compliance team, responsible for ensuring adherence to U.S. export control laws, the defendants staged thousands of “dummy” servers—non-working, physical replicas of the U.S. Manufacturer’s servers—for inspection at the locations where Company-1 was purportedly storing the servers it had purchased from the U.S. Manufacturer. However, the actual servers purchased by Company-1 from the U.S. Manufacturer had already been unlawfully shipped to China.

 

https://www.justice.gov/opa/pr/three-charged-conspiring-unlawfully-divert-cutting-edge-us-artificial-intelligence

 

See our article on this topic at: The Compliance Illusion – FD Associates, Inc.

 

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March 20, 2026: The Department of Justice announced the former Chief Executive Officer of Nodus International Bank (Nodus Bank), a Puerto Rican international bank, plead guilty on March 19, 2026 for leading a scheme to fraudulently obtain at least $24.9 million from Nodus Bank and conspiring to evade U.S. sanctions against Venezuela.

 

“This defendant used his position as CEO to siphon more than $24 million, hide conflicts of interest, and help drive the bank’s collapse,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “The scheme also involved efforts to evade U.S. sanctions tied to Venezuela’s state-owned oil company, PDVSA. As a career prosecutor and former state trial judge, I’ve learned that following the money reveals the truth. Here, it exposed both fraud and sanctions violations. We will hold accountable anyone who abuses our financial system for personal gain.”

 

Tomás Niembro Concha, 64, of Miami, Florida, conspired with others to siphon money from Nodus Bank, ultimately leading to the bank’s failure in 2023. Niembro and his co-conspirators concealed from other Nodus Bank board members and executives and the bank’s regulator that certain investments and loans were for the benefit of Niembro and Board Chairman Juan Ramirez, in violation of Puerto Rican law. From 2017 to 2023, Niembro, Ramirez and others caused Nodus Bank to invest $11 million in a Miami-based lender so those funds could be loaned to Niembro and Ramirez for their own benefit. Niembro and his co-conspirators knew that these transactions were illegal and concealed their conduct through the sham investments.

 

Between January 2018 and September 2021, Niembro and Ramirez also fraudulently induced Nodus Bank’s board and comptroller to agree to buy at least 47 promissory notes totaling approximately $25.3 million from Nodus Finance, a Miami-based company that Niembro and Ramirez jointly owned, so they could use the proceeds of the transactions for themselves.

 

In early March 2023, Nodus’s regulator, the Office of the Commissioner of Financial Institutions of Puerto Rico (OCIF), notified the bank it would be placed into liquidation. Niembro and Ramirez fraudulently caused Nodus Bank to accept a loan portfolio from Nodus Finance to pay down the debt from the 47 promissory notes.

 

Moreover, between 2021 and 2023, Niembro conspired with others to conduct prohibited financial transactions with an individual designated as a Specially Designated National (SDN) by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for providing material support to Venezuela’s state-owned oil company, Petróleos de Venezuela, S.A. (PDVSA). To satisfy an outstanding loan of approximately $2.5 million that the SDN’s company had with Nodus Bank prior to the imposition of sanctions, Niembro and the SDN devised a scheme to cause Nodus Bank to foreclose on the SDN’s home in Southampton, NY — for which they obtained OFAC authorization — but separately reached a “private” agreement to induce Nodus Bank to sell the property back to the SDN for $4 million through a front company — a transaction that was strictly prohibited by U.S. sanctions and not otherwise licensed by OFAC.

 

Niembro pleaded guilty to a two-count Information charging conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (IEEPA). Each charge carries a maximum penalty of 20 years in prison. Niembro’s sentencing has been scheduled for June 8. As part of his plea agreement, Niembro agreed to forfeit at least $16.9 million, which represents the value of the proceeds he derived from the wire fraud conspiracy. A federal judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

 

https://www.justice.gov/opa/pr/former-bank-ceo-pleads-guilty-multimillion-dollar-wire-fraud-conspiracy-and-venezuela

 

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March 25, 2026: The Department of Justice charged Stanley Yi Zheng, Matthew Kelly, and Tommy Shad English with conspiring to commit smuggling and export control violations. The three defendants are alleged to have sought millions of dollars’ worth of export-controlled computer chips from a California-based computer hardware company for illegal shipment to China through Thailand.

 

“Zheng, Kelly, and English allegedly conspired to sell millions of dollars’ worth of American-made AI computer chips to buyers in China, in clear violation of U.S. export controls,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “As our foreign adversaries escalate their efforts to dominate the field of artificial intelligence, we are seeing them employ increasingly brazen schemes to illegally acquire valuable U.S. technology. Enforcing export controls is critical to our work safeguarding America’s economic and national security, and the FBI will continue working with our partners to protect our nation’s innovation and hold accountable those seeking to profit by supplying hostile nation states.”

 

According to the criminal complaints and other information presented in court: In or about May 2023, Zheng, Kelly, and English began conspiring together to obtain computer servers with export-controlled computer chips from a California-based computer hardware company (Company-1) and ship them to Thailand with an ultimate destination of China, in violation of U.S. law. In doing so, the three defendants used the names of Thailand-based companies as the purported purchasers of the computer servers when in fact the co-conspirators intended for the U.S.-origin AI chips to be diverted to China.

 

In Oct. 2023, English, purporting to act on behalf of a Thailand-based company, ordered 750 computer servers for approximately $170 million from Company-1. Of the 750 computer servers, 600 contained a computer chip that was controlled on the U.S. Commerce Control List and required a license for export to China. In placing that order, English signed an “Advanced Computing Certification,” certifying that the computer servers were not destined for China or any other country subject to heightened export requirements.

 

In Jan. 2024, English transferred over $20 million to Company-1 as partial payment for the Oct. 2023 order. In Jan. 2024, when discussing via email an upcoming compliance review for the Oct. 2023 order, English asked Company-1 to add Zheng and Kelly to the email thread, which prompted a response from Company-1 noting, among other things, that Zheng’s company was based in China and that it was “odd” that no one from the Thailand-based company was in the list of carbon copy recipients. Company-1 also commented that “China is an embargoed country restricted by the US government. US companies are restricted from selling to businesses or end users headquartered in China.”

 

In early Feb. 2024, additional review of the Oct. 2023 order was conducted by the California-based manufacturer of the computer chips that would be inside 600 of the servers English had ordered (Company-2). Company-2’s efforts to verify the end user of the computer chips in Thailand were unsuccessful. Ultimately, the Oct. 2023 purchase was not completed.

 

While the Oct. 2023 deal lost momentum, in April 2024, English, purporting to act on behalf of a second Thailand-based company, sought to order from Company-1 another 500 computer servers that contained an export-controlled computer chip. In doing so, English signed an End User Certification stating that the Thailand-based company was the end user for the purchase. This deal, like the Oct. 2023 deal, ultimately was unsuccessful.

 

Text messages obtained through the investigation illustrated aspects of the conspiracy and revealed that Zheng, English, and Kelly discussed, among other things, “fake” corporate niceties to help complete the computer chip purchases, the value of the computer chips in China, and recruitment of others to participate in the scheme.

 

This case is being investigated by the Department of Commerce’s Bureau of Industry & Security, the Defense Criminal Investigative Service, Homeland Security Investigations, and the Federal Bureau of Investigation as the result of a tip that BIS received through an email account listed on the BIS website.

 

Assistant U.S. Attorney Samir Kaushal of the United States Attorney’s Office for the Northern District of Georgia and Trial Attorney Brett Ruff of the National Security Division’s Counterintelligence and Export Control Section are prosecuting the case.

 

https://www.justice.gov/opa/pr/chinese-national-and-two-us-citizens-charged-conspiring-smuggle-artificial-intelligence

 

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March 30, 2026: Manfred Gruber, an Italian national, plead guilty to conspiracy to commit export control violations. Gruber illegally exported ammunition worth over $540,000 from the United States to Kyrgyzstan, via companies that the defendant and his co-conspirator controlled in Italy. After reaching Kyrgyzstan, most of this ammunition was subsequently reexported to Russia.

 

In January 2026, Sergei Zharnovnikov, a Kyrgyzstan-based co-conspirator of the defendant, was sentenced to 39 months’ imprisonment after pleading guilty to violating the Export Control Reform Act.

 

“Manfred Gruber put many lives at risk by illegally supplying Russia with hundreds of thousands of dollars’ worth of American-made, military-grade ammunition to advance its war in Ukraine,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division.

 

“The defendant used multiple companies to hide his scheme to send military‑grade ammunition to Kyrgyzstan, before it was reexported to Russia to support its war effort,” stated United States Attorney Joseph Nocella for the Eastern District of New York. “I commend our partners at the FBI and the Department of Commerce for uncovering this deadly scheme and swiftly bringing Gruber to justice.”

 

https://www.justice.gov/opa/pr/arms-dealer-pleads-guilty-conspiring-export-american-made-ammunition-used-war-against

 

Sanctions

 

Department of Commerce, Bureau of Industry & Security

 

March 31, 2026: 91 Fed. Reg. 15948: The Department of Commerce, Bureau of Industry & Security issued an order renewing temporary denial of export privileges of Aviastar – TU (”Aviastar”).

 

https://www.federalregister.gov/documents/2026/03/31/2026-06161/aviastar-tu-5-b-7-leningradsky-prospect-g-moskva-125040-moscow-russia-order-renewing-temporary)

 

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

 

The following is a summary of OFAC actions for March 1 through March 31, 2026.

 

• OFAC issued 10 new/amended General Licenses and 13 new Frequently Asked Questions related to Venezuela Sanctions.
• OFAC issued 5 new General Licenses and 2 new Frequently Asked Questions related to Russia Sanctions.
• OFAC issued 1 new General License related to Belarus Sanctions.
• OFAC issued 1 new General License related to Iran Sanctions.
• OFAC issued 1 new General License related to the sanctioning of the Rwanda Defence Force.
• OFAC issued Guidance on Sham Transactions and Sanctions Evasion.
• OFAC added to the Specially Designated Nationals List individual and entities from:
  • Rwanda, notably the Rwanda Defence Force, for supporting human rights abuse in the Democratic Republic of the Congo;
  • Sudan as a result of recent designation as a Foreign Terrorist Organization;
  • Turkey and Indonesia as a result of being designated as sham organizations that directly fund Hamas, a Foreign Terrorist Organization;
  • N. Korea because they systematically defrauded U.S. persons to fund N. Korea’s Weapons of Mass Destruction Programs;
  • Canada, Lebanon, Poland, Slovenia, and Syria for laundering and raising funds for Hizballah, a Foreign Terrorist Organization.

 

Detailed information regarding the OFAC can be found at https://ofac.treasury.gov/recent-actions.

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

 

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

persons denied export privileges by the United States Government.

 

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

 

REGULATORY UPDATES

 

President

 

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

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

 

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

 

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Establishing An American First Arms Transfer Strategy

 

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

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

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

 

An America First Arms Transfer Strategy.

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

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

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

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

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

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

 

Eliminating Inefficiencies in American Arms Transfers

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

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

 

Enhancing Accountability and Transparency

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

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

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

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

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

 

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

 

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Addressing Threats to the United States by the Government of Iran

 

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

 

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

 

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

 

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

 

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

 

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Continuation of the National Emergency With Respect to Ukraine

 

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

 

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

 

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Continuation of the National Emergency With Respect to Venezuela

 

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

 

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

 

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

 

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

 

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

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

 

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Ending Certain Tariff Actions

 

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

 

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

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

 

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

 

DDTC Name And Address Changes Posted To Website

 

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

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

 

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

To: Honeywell Aerospace Belgium B.V.

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

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

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

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

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

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

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

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

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

To: Qnity Electronics, Inc. as subsidiaries.

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

To: Qnity Electronics, Inc. as subsidiaries.

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

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

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

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

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

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

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

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

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

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

To: Ryoshin Technica Corporation

• From: Ryoshin Technica Corporation

To: Mitsubishi Electric Infrastructure Technica Corporation

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

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

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

• From: Schenker NV Noorderlaan 147 2030 Antwerp, Belgium

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

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

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

• From: Schenker OY, Finland

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

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

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

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

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

• From: Schenker AS Alnabruveien 15 0668 Oslo, Norway

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

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DDTC Final Commodity Jurisdiction Determinations Posted To Website

 

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

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

 

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

 

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Notifications to the Congress of Proposed Commercial Export Licenses

 

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

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

 

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DDTC Frequently Asked Questions (FAQs)

 

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

 

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

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

 

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

 

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

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

Directorate of Defense Trade Controls

2401 E Street, NW

Suite H1200

Washington, DC 20522-0112

 

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

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

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

 

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

 

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

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

 

• • Full name, and
  • Social Security Number.

 

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

 

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

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

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

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Department of Defense, Defense Security Cooperation Agency (DSCA)

 

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

 

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

 

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

 

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

 

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DCSA Notifies Congress of Potential FMS Sale to Iraq

 

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

 

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

 

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

 

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DCSA Notifies Congress of Potential FMS Sale to Ukraine

 

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

 

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

 

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

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

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

 

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

 

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

 

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

 

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Future Announcements Of Major Arms Sales

 

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

 

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

 

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

 

Conforming Change to the Export Administration Regulations for Cambodia

 

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

 

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

 

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

 

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

 

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

 

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

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

 

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Office of Foreign Assets Control (OFAC)

 

Launch of Voluntary Self-Disclosure Portal

 

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

 

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

 

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

 

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

 

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

 

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

 

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U.S. Census Bureau

 

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

 

February 18, 2026:

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

Additional information about the ITAR exemption can be found:

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

 

Fact sheet can be found at:

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

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How to Resolve Common AES Response Messages

 

February 19, 2026:

 

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

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

Response Code:  643

Narrative:         Quantity (2) Must Be Greater Than Zero

Severity:           Fatal

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

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

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

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

Appendix A – Commodity Filing Response Messages.

 

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License Type Code Requirements

 

February 26, 2026:

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

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

 

LATEST SANCTIONS FINES & PENALTIES

 

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

 

Fines and Penalties

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

Transfers in Vendor Workflows” at the attached Link

 

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

 

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

 

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

 

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

 

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

 

The violations are the result of the following:

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

 

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

 

Sanctions

 

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

 

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

 

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

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

 

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

 

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

 

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

 

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

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

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

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

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

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

 

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

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

 

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

 

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

 

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

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

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

 

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

 

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

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

 

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

 

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

 

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

 

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

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

 

Notably, GL 46 does not authorize:

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

 

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

 

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

 

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

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

 

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

 

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

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

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

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

 

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

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

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

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

 

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

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

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

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

 

This general license does not authorize:

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

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

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

(4) Any transaction involving a blocked vessel;

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

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

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

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

 

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

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

 

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

 

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

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

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

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

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

 

This general license does not authorize:

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

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

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

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

(5) Any transaction involving a blocked vessel.

 

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

 

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

 

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

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

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

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

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

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

 

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

 

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

 

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

 

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

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

 

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

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

 

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

 

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

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

 

This general license does not authorize:

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

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

(3) Any transaction involving a blocked vessel.

 

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

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

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

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

 

This general license does not authorize:

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

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

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

(4) Any transaction involving a blocked vessel.

 

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

 

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

 

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

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

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

 

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

 

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

Top of Form

 

Bottom of Form

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

 

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

Top of Form

Answer

Bottom of Form

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

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

 

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

 

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

 

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

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

 

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

 

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

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

 

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

 

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

 

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

 

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

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

 

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

 

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

 

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

 

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

 

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

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

 

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

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

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

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

 

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

 

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

 

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

 

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

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

 

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

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

 

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

 

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

 

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

 

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

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

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

 

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

 

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

 

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

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

 

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

 

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

 

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

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

 

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

 

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

 

This general license does not authorize:

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

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

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

 

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

 

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

Top of Form

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

 

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

 

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

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

 

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

 

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

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

 

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

 

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

 

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

 

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

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

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