, Author at FD Associates, Inc.

What the Latest ITAR Revisions Mean for Small Businesses – September 2025

By George (Jorge) Cánovas

Vice President – Compliance

FD Associates, Inc.

When most people hear the phrase International Traffic in Arms Regulations or ITAR, they imagine crates of missiles, stealth fighters, or nuclear warheads. They do not picture an underwater robot used by a marine survey company, a high-performance antenna that can be fitted on a commercial airframe, or a piece of body armor sold through a subcontractor. Yet those are precisely the kinds of items the law can capture. Many of you are specifically aware of this and how nuances can matter to include end users and forward manufacturing.

For readers who have never worked with these rules, or work tangentially with the ITAR in a business development or management position, the ITAR is the regulatory framework administered by the U.S. Department of State (DoS) that controls exports of defense articles, services, and related technical data. The backbone of the system is the U.S. Munitions List, a dense catalog of categories ranging from firearms to avionics to chemical precursors. If your work or your businesses work appears on that list, you cannot transfer it abroad or share it with foreign persons inside the United States without approval. And “export” does not just mean shipping. Letting a foreign engineer review controlled design drawings in your office can be treated exactly the same way as sending a crate of parts across a border.

This is not an academic concern. A small business that never thought of itself as part of the defense sector can suddenly find that its products, software, or even research activities fall under ITAR, which can occur when the DoS’s Directorate of Defense Trade Controls (DDTC) modifies the rules. When that happens, the company must apply for licenses through the DDTC, keep meticulous records, and adapt to a new world of restrictions and oversight. Licenses can take weeks or months and may come with conditions that change how and when you deliver to customers. Penalties for violations are severe, running from multimillion-dollar fines to loss of export privileges. It can also go the other way, and relive companies if the items they produce, sell, etc., have been removed.

A Final Rule with Far-Reaching Impact

On August 27, 2025, the State Department published a final rule in the Federal Register amending key sections of ITAR. This rule revises the U.S. Munitions List, updates definitions, and creates a new license exemption. It builds on an interim rule issued in January 2025 and is explicitly framed as part of a broader strategy to streamline defense trade and deepen cooperation with U.S. allies and partners[1]. The timing was no accident. A few months earlier, President Biden signed Executive Order 14268, Reforming Foreign Defense Sales to Improve Speed and Accountability, which directed the Departments of State and Defense to review the U.S. Munitions List to ensure it focuses on the most sensitive technologies while clearing away unnecessary restrictions.

The rule removes several items that the government no longer believes provide a critical military advantage. Certain GNSS anti-spoofing and anti-jam systems, some controlled reception pattern antennas, airborne collision avoidance system antennas, and tungsten- or steel-based lead-free birdshot are all being shifted off the USML. Once removed, they fall under Department of Commerce jurisdiction and the Export Administration Regulations (EAR), meaning they remain regulated for export but in a less restrictive framework.

At the same time, the final rule strengthens control. It makes permanent temporary controls on items “specially designed” for the F-47 Next Generation Air Dominance Platform[2]. It clarifies definitions around advanced military aircraft. It also responds to public comments that highlighted the civil use of large autonomous underwater vehicles. Recognizing the importance of these systems to sectors like energy, telecommunications, and marine research, the rule creates a new license exemption that allows U.S. companies to participate in operations involving certain Underwater Unmanned Vehicles performing functions such as inspecting offshore pipelines, repairing telecom cables, or conducting search and rescue missions, without the full weight of ITAR licensing. This is a striking acknowledgment of the dual-use reality of twenty-first century technology.

DDTC also emphasized that these revisions are not final. The agency continues to welcome input from the public, inviting companies and researchers to identify items they believe should be revised, removed, or added in future updates. This willingness to consult is unusual in the world of arms control and underscores a trend toward more transparent, iterative management of the U.S. Munitions List.

If your company works in aerospace, maritime technology, advanced electronics, protective equipment, chemicals or any sector that develops products with potential dual-use application, we strongly suggest the you read the attached Federal Register Notice . The revision may address technology that your company handles, makes or develops. The revision reshapes what falls under the ITAR and what shifts to Commerce, falling into the EAR. These changes carry real consequences for how you classify your products, pursue contracts, and handle foreign partnerships. Even if you have never considered yourself part of the defense supply chain, these changes could quietly alter your obligations.

Overview of the Changes In-Process

Items removed from the U.S. Munitions List (now under EAR) under the new revisions[3]:

Certain Global Navigation Satellite System (GNSS) anti-spoofing systems
Certain GNSS anti-jam systems
Controlled Reception Pattern Antennas (CRPAs) for Position, Navigation, and Timing (PNT)
Airborne Collision Avoidance System (ACAS) antennas
Tungsten- and steel-based lead-free birdshot projectiles

Items added or clarified under ITAR control[4]:

Items “specially designed” for the F-47 Next Generation Air Dominance Platform (now permanently controlled) USML Category VIII(a)(7) – permanently controls items specially designed for advanced military aircraft, including the F-47.
Foreign advanced military aircraft, explicitly defined to include those with AESA (Active Electronically Scanned Array) fire-control radars, integrated electronic warfare and signature management systems, and beyond-visual-range targeting capability USML Category XI(b) – electronic systems, equipment, or software specially designed for military electronic warfare, countermeasure, and surveillance functions.
Body armor and protective equipment, revised to reflect the current National Institute of Justice performance standards (USML X)
Energetic materials and chemical precursors, including poly-NIMMO and CL-20-related compounds (USML V)
Revised definitions for certain electronic warfare equipment, excluding some civil navigation gear but tightening controls on military countermeasure, see USML Category XI(b)

New ITAR Exemption:

ITAR License Exemption ITAR §123.16(b)(15) (newly created exemption in the Final Rule) is added for Unmanned Underwater Vehicles (UUVs) under 8,000 pounds may be exported temporarily without an ITAR license when used for civil purposes such as scientific research, natural resource exploration, infrastructure inspection or repair (including oil and gas pipelines and telecom cables), and search and rescue operations.

What It Means for Small Businesses

For a small company, the consequences are immediate and tangible. A firm producing antennas or sensors may suddenly find that while many models are now subject to the EAR, certain advanced or military-configured versions remain ITAR-controlled. That reclassification affects the markets the firm can serve, the partnerships it can form with larger primes, and the way investors assess its risk profile.

Consider also the opportunities. A marine robotics startup might benefit from the new UUV exemption. Instead of months of waiting on a license, it could send a vehicle overseas for a civil infrastructure project with far fewer delays provided the company is registered with DDTC. That advantage is real, but only if the company can prove it qualifies, document the mission, and keep meticulous control of the platform.

A chemical supplier may need to revisit formulations now listed by name in the U.S. Munitions List or a software developer whose algorithms strengthen satellite navigation against spoofing may find itself removed from the ITAR and now under the EAR jurisdiction, which is less restrictive for some destinations but carries its own set of risks.

The common thread is that export classification is critical to all exporters. ITAR is not just associated with missiles, tanks and stealthy aircraft, it touches electronics, materials science, robotics, and software.

For small businesses, the difference between opportunity and liability often lies in whether leadership is paying attention to how their company products, software, technology and services are controlled and the reason that executives must clearly understand the liabilities, as well as business strategic opportunities. If your business can navigate these opportunities correctly and with foresight, you will be the company with the competitive edge, which equates to profits.

Foreign Businesses Should Take Notice

These ITAR US Munitions List revisions should also matter deeply for foreign companies. ITAR follows the item, not just the U.S. manufacturer. A distributor in Europe handling American-made products cannot re-export them freely without reexport authorization. A shipyard in Asia servicing vessels with U.S. navigation equipment must comply with U.S. licensing rules. Even a foreign research consortium that touches U.S. technical data can be pulled into the ITAR regime. Foreign companies need to be knowledgeable on specific changes to the ITAR and the EAR if they do business in the defense sector.

What may not be obvious is that compliance can be a competitive advantage. Executive Order 14268 is explicit about its intent: to streamline defense trade, facilitate cooperation with allies, and reduce unnecessary burdens. For a foreign company seeking to enter the U.S. defense supply chain, demonstrating a mature understanding of ITAR and the EAR is not a box-checking exercise it is a selling point. American primes and government customers increasingly want foreign partners who can handle controlled technology without fear of violations. Firms that invest in compliance now are better placed to win contracts, attract U.S. partners, and be viewed as credible contributors to joint defense projects.

The executive order behind this rule makes the logic plain, that is; by focusing the U.S. Munitions List on the most sensitive technologies and easing controls elsewhere, the U.S. government is trying to speed up defense trade with trusted allies. Foreign businesses that align early, adopt compliance systems, and train their staff are positioning themselves not only to stay safe but also to grow faster in a global marketplace that prizes reliability and accountability.

A Note on Research Institutions

Although this article focuses on businesses, academic research institutions are not immune to the ITAR and the evolution of changes in the regulations. University labs often work with technologies that straddle the civil–military divide. An engineering department experimenting with advanced antennas, a marine science institute operating an underwater vehicle, or a chemistry lab developing new energetic materials can all find themselves pulled into ITAR. The presence of foreign students adds further complexity, since allowing access to controlled data counts as an export under the law. U.S. institutions operating off U.S. soil can find themselves in even a more complex situation. What is clear is that institutions that fail to update their technology control plans, and their internal compliance programs risk both regulatory exposure, reputational harm and the loss of valuable grant opportunities.

Final Thoughts

The September 2025 rule is not simply a regulatory housekeeping exercise. It is part of a deliberate strategy to make the U.S. export control system more precise, more responsive, and more supportive of international cooperation. For small businesses, it is a reminder that compliance is inseparable from competitiveness. For foreign firms, it is a signal that mastering ITAR and the EAR is a way to distinguish themselves as reliable partners in the U.S. defense market. And for research institutions, it is another push to integrate export awareness into daily life.

In the end, these revisions tell a story of adaptation, as it is clear that the U.S. government wants to protect the warfighter’s edge without smothering innovation. Businesses that fully embrace and comply, whether in Virginia or Paris, will not only stay on the right side of the law but will also gain an advantage in a world where compliance is itself a mark of credibility.

Please contact FD Associates if you have any questions or our team of experts can help to position your enterprise to have a clear competitive edge and ensure profits, not liabilities end up on your P&L statement.

© FD Associates, Inc., 703-847-5801 – 1945 Old Gallows RD, Suite #530, Vienna, VA 22182

What the Latest ITAR Revisions Mean for Small Businesses – September 2025 Read More »

AUGUST 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through August 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

REGULATORY UPDATES

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

Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses

August 8, 2025: 90. Fed. Reg. 33462: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.

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

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International Traffic in Arms Regulations: U.S. Munitions List Targeted Revisions

August 27, 2025: 90 Fed. Reg. 41778: The Department of State published a final rule in the Federal Register to amend §§ 121.0, 121.1, and 126.9 of the International Traffic in Arms Regulations (ITAR) making revisions to the U.S. Munitions List (USML), adding and updating definitions, and creating a new license exemption.

This rule is one in a series of rules that streamlines defense trade and facilitates cooperation with U.S. allies and partners while reducing the regulatory burden for exporters, in support of the President’s April 9, 2025, Executive Order (E.O.) 14268, “Reforming Foreign Defense Sales to Improve Speed and Accountability,” which directs the Departments of State and Defense to review the USML to focus its protections.

This final rule expands on the interim final rule published January 17, 2025 (the IFR), and makes other changes based on DDTC’s ongoing assessments and periodic review of the USML. The revisions and the new exemption will take effect on September 15, 2025.

The rule includes revisions designed to promote the competitiveness of the U.S. defense industrial base, while continuing to protect the warfighter’s edge. With this rule, DDTC also takes steps to reduce unnecessary regulatory burden and act consistently with the President’s order to focus the USML on the most sensitive technologies.

This rule removes the following items from the USML, as the Department has determined they no longer provide a critical military or intelligence advantage:

Certain Global Navigation Satellite Systems (GNSS) anti-spoofing and GNSS anti-jam systems
Certain Controlled Reception Pattern Antennas (CRPAs) for Position, Navigating, and Timing (PNT) purposes
Airborne Collision Avoidance System (ACAS) antennas
Tungsten- and steel-based lead-free birdshot projectiles

Items removed from the USML will become subject to Commerce’s Export Administration Regulations (EAR).

In response to public comments identifying commercial applications of some extra-large autonomous underwater uncrewed vessels (UUVs) that will be described in USML Category XX(a)(10), this final rule adds a new exemption from ITAR licensing requirements to facilitate U.S. participation and collaboration in certain tasks that use these UUVs, specifically: scientific research, natural resource exploration, certain commercial or civil infrastructure operations (e.g., oil and gas pipeline inspections, telecommunication cable repairs), or search and rescue operations.

This rule also includes revisions that improve the clarity and usability of the regulations, and the preamble to the rule provides clarifications in response to public comments on the IFR. Finally, this rule makes permanent the existing temporary controls on items specially designed for the F-47 Next Generation Air Dominance Platform.

Although it is not seeking public comment in this final rule, the Department of State welcomes submissions from members of the public identifying specific descriptions of items that, in their view, the Department of State should consider revising, removing, or adding to the USML in future rulemaking. Members of the public are often uniquely positioned to provide information that can assist the Department of State in its review of the USML, including technology developments, commercial use of defense technology, and industry interpretation and application of particular terminology.

https://www.federalregister.gov/documents/2025/08/27/2025-16382/international-traffic-in-arms-regulations-us-munitions-list-targeted-revisions

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60-Day Notice of Proposed Information Collection: Statement of Political Contributions, Fees, and Commissions Relating to Sales of Defense Articles and Defense Services

August 28, 2025: 90. Fed. Reg. 41866: The Department of State is seeking Office of Management and Budget (OMB) approval for the information identified in the title. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collection to OMB.

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

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60-Day Notice of Proposed Information Collection: Nontransfer and Use Certificate

August 28, 2025: 90 Fed. Reg. 41471: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described in the title. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collection to OMB.

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

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DDTC Name And Address Changes Posted To Website

August 12 through 13, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at

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

Name change of ATLAS ELEKTRONIK GmbH to TKMS ATLAS ELEKTRONIK GmbH due to acquisition;
Name change of GF Machining Solution AG to United Machining Mill AG due to acquisition;
Name and address change of NVL B.V. Co. ZKG, Zum Alten Speicher 11 28759 Bremen, Germany to Civmec Limited (CVL), 16 Nautical Drive, Henderson, WA due to change in ownership; and
Name and address change of Luerssen Australia Pty Ltd. (Luerssen), 16 Nautical Drive, Henderson, WA 6166 to Civmec Defence Industries (CDI), 16 Nautical Drive, Henderson, WA 6166 due to ownership change.

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Ukraine

August 5, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment; repair services; and long-term sustainment support for M777 howitzers. The following non-MDE items will be included: technical assistance; training; publications; and other related elements of logistics and program support. The estimated total cost is $104 million. The principal contractor will be BAE Systems, located in Barrow-in-Furness, England. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4266194/ukraine-equipment-repair-services-and-sustainment-support-for-m777-howitzers

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

August 5, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy transportation and consolidation services in support of security assistance programs and other related elements of logistics and program support. The estimated total cost is $99.5 million. The principal contractor(s) will be determined from approved vendors. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4266161/ukraine-transportation-and-consolidation-services

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DSCA Notifies Congress of Potential FMS Sale To Australia

August 6, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Australia has requested to buy equipment and services to support maintenance of its MC-55A aircraft fleet, to include major and minor modifications; spare parts; consumables and accessories; repair and return support; U.S. government and contractor engineering; technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $404 million. The principal contractor will be L3 Harris, located in Greenville, TX. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4267141/australia-mc-55a-baseline-2-upgrade

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DSCA Notifies Congress of Potential FMS Sale To Canada

August 8, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Canada has requested to buy a fleet of up to sixty (60) Joint Light Tactical Vehicles (JLTVs); and up to nine (9) JLTV cargo trailers. The following non-MDE items will also be included: communication equipment; mobility equipment; lethality and survivability enhancements; spare and repair parts; special tools and test equipment (STTE); technical manuals and publications; maintenance trainers; new equipment training; total package fielding support; depot level maintenance/repair and return support; U.S. Government and contractor technical, engineering, and logistics personnel services; and other related elements of logistics and program support. The estimated total program cost is $160 million. The principal contractors will be AM General, LLC, located in Auburn Hills, MI and Mishawaka, IN. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4270288/canada-joint-light-tactical-vehicles

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DSCA Notifies Congress of Potential FMS Sale To Nigeria

August 13, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Nigeria has requested to buy one thousand two (1,002) MK-82 general purpose 500 lbs bombs; one thousand two (1,002) MXU-650 Air Foil Groups (AFGs) for 500 lb Paveway II GBU-12; five hundred fifteen (515) MXU-1006 AFGs for 250 lbs Paveway II GBU-58; one thousand five hundred seventeen (1,517) MAU-169 or MAU-209 computer control group (CCG) for Paveway II GBU-12/GBU-58; one thousand two (1,002) FMU-152 joint programmable fuzes; and five thousand (5,000) Advanced Precision Kill Weapon System II (APKWS II) all-up-rounds (AURs) (consisting of one each WGU-59/B guidance section (GS); high-explosive warhead; and MK66-4 rocket motor). The following non-MDE items will also be included: FMU-139 joint programmable fuzes; bomb components, impulse cartridges, and high-explosive and practice rockets; integration support and test equipment; U.S. Government and contractor technical, engineering, and logistics personnel services; and other related elements of logistical and program support. The total estimated program cost is $346 million. The principal contractors will be RTX Missiles and Defense, Tucson, AZ; Lockheed Martin Corporation, Archibald, PA; and BAE Systems, Hudson, NH. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4273754/nigeria-munitions-precision-bombs-and-precision-rockets

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DSCA Notifies Congress of Potential FMS Sale To Bahrain

August 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Bahrain has requested to buy four (4) M142 High Mobility Artillery Rocket Systems (HIMARS); and three (3) International Field Artillery Tactical Data Systems. The following non-MDE items will also be included: M28A2 Low Cost Reduced Range Practice Rocket Pods; High Mobility Multi-Purpose Wheeled Vehicle Fire Direction Centers; M1084A3 HIMARS resupply vehicles; HIMARS Driver Vision Enhancer systems; AN/PSN-13 Defense Advanced GPS Receiver; support and test equipment; simulators; generators; integration and test support; spares and repair parts; communications equipment; software delivery and support; facilities and construction support; publications and technical documentation; personnel training and training equipment; support equipment; U.S. Government and contractor engineering, technical, and logistics support services; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $500 million. The principal contractor will be Lockheed Martin, located in Grand Prairie, TX. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4274789/bahrain-m142-high-mobility-artillery-rocket-system

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DSCA Notifies Congress of Potential FMS Sale To Australia

August 19, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Australia has requested to buy one hundred sixty-one (161) Lightweight Command Launch Units (LwCLU) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $6.3 million ($0 in Major Defense Equipment (MDE)), included Javelin Life Cycle Support (LCS) and U.S. Government and contractor technical assistance. This notification is for one hundred sixty-one (161) Lightweight Command Launch Units (LwCLU). The following non-MDE items will also be included: Javelin LwCLU Basic Skills Trainer; missile simulation rounds and battery coolant unit; electronic technical manual and operator manuals; life cycle support; physical security inspection; spare parts; System Integration and Check Out; U.S. Government and contractor technical assistance, engineering, logistics, and personnel services; tool kits; training; and other related elements of logistics and program support. The estimated total cost is $97.3 million. The principal contractors will be the Javelin Joint Venture between RTX Corporation, located in Arlington, VA; and Lockheed Martin, located in Orlando, FL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4279065/australia-javelin-lightweight-command-launch-unit

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DSCA Notifies Congress of Potential FMS Sale To United Kingdom

August 26, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the United Kingdom has requested to buy equipment and services to support contractor logistics support sustainment for the United Kingdom’s C-17 (Globemaster III) aircraft fleet. The following non-MDE items will be included: engine components, parts, and accessories; major and minor modifications; computer program identification numbers; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $861 million. The principal contractor will be The Boeing Company, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4285993/united-kingdom-c-17-globemaster-iii-aircraft-sustainment-support

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DSCA Notifies Congress of Potential FMS Sale To Poland

August 26, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy equipment and services in support of F-35 sustainment, including the aircraft engine Component Improvement Program (CIP). The following non-MDE items will be included: major and minor modifications; spare parts, consumables and accessories, and repair and return support; weapon system support, including software; classified software and delivery support; classified and unclassified publications and technical documentation; clothing, textiles, and individual equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.85 billion. The principal contractor will be General Electric Aerospace, located in Evendale, OH. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4285956/poland-f-35-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

August 28, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy up to three thousand three hundred fifty (3,350) Extended Range Attack Munition (ERAM) missiles and three thousand three hundred fifty (3,350) Embedded Global Positioning System (GPS)/Inertial Navigation Systems (INS) (EGI) with Selective Availability Anti-Spoofing Module (SAASM), Y-Code, or M-Code. The following non-MDE items will be included: missile containers; stoker pylons; component parts and support equipment; spare parts, consumables and accessories, and repair and return support; weapons software and support equipment; mission planning system hardware; classified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $825 million. The principal contractors will be Zone 5 Technologies and CoAspire. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4289280/ukraine-air-delivered-munitions

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

August 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services to support sustainment of its Patriot air defense systems. The following non-MDE items will be included: classified and unclassified spare parts; maintenance support; classified and unclassified software and software updates; system modifications and associated modification kits; test equipment; communication equipment and associated accessories; integration services; repair and return; storage; tooling; Field Surveillance Program; International Engineering Services Program; maintenance support equipment; U.S. Government and contractor representative technical assistance; training; engineering and logistics support services; classified and unclassified publications and technical documentation; classified software; and other related elements of logistics and program support. The estimated total program cost is $179.1 million. The principal contractors will be RTX Corporation, located in Arlington, VA; and Lockheed Martin, located in Bethesda, MD. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4290514/ukraine-patriot-air-defense-system-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

August 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy an extension of satellite communications services for its Starlink terminals. The following non-MDE items will be included: U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $150 million. The principal contractor for this effort will be Starlink Services, located in Hawthorne, CA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4290506/ukraine-satellite-communications-services

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DSCA Notifies Congress of Potential FMS Sale To Denmark

August 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Denmark has requested to buy thirty-six (36) PATRIOT MIM-104E guidance enhanced missile-tactical (GEM-T) ballistic missiles; twenty (20) PATRIOT Advanced Capability-3 (PAC-3) Missile Segment Enhancement (MSE) missiles; two (2) AN/MPQ-65 radar sets; two (2) Engagement Control Stations (ECS); two (2) Radar Interface Units (RIU) modification kits; six (6) PATRIOT M903A2 launching stations (LS); six (6) Integrated Battle Command System (IBCS) Software Launcher Integrated Network Kits (LINKs); two (2) IBCS Engagement Operations Centers (EOCs); two (2) IBCS Integrated Collaborative Environments (ICE); six (6) IBCS integrated fire control network (IFCN) relays; and two (2) Electrical Power Plants III (EPP III). The following non-MDE items will also be included: communications equipment including, but not limited to, AN/TPX–57A identification friend or foe (IFF), Defense Advanced Global Positioning System (GPS) Receiver (DAGR), AN/PYQ-10 Simple Key Loader, KIV-77 encryptor, KG-250X Inline Network Encryptor, IPS-250X HAIPE Encryptor, future Combat Net Radio, and AN/PRC-163 radio; tools and test equipment; support equipment; generators; publications and technical documentation; training equipment including the Air Defense Reconfigurable Trainer; spare and repair parts; personnel training; Technical Assistance Field Team support; U.S. Government and contractor technical assistance and services, engineering, and logistics support; System Integration and Checkout; field office support; and other related elements of logistics and program support. The estimated total cost is $8.5 billion. The principal contractors will be RTX Corporation, located in Arlington, VA; Lockheed-Martin, located in Dallas, TX; and Northrop Grumman, located in Falls Church, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4290506/ukraine-satellite-communications-services

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

August 19, 2025: 90 Fed. Reg. 40326: The Department of Commerce announced the addition of 407 product categories to the list of “derivative” steel and aluminum products covered by Section 232 sectoral tariffs. As a result, the steel and aluminum content of these products will be subject to a duty rate of 50%. This action covers wind turbines and their parts and components, mobile cranes, bulldozers and other heavy equipment, railcars, furniture, compressors and pumps, and hundreds of other products.

Under Secretary of Commerce for Industry and Security Jeffrey Kessler stated:

“This action expands the reach of the steel and aluminum tariffs and shuts down avenues for circumvention – supporting the continued revitalization of the American steel and aluminum industries.”

This is the latest in a series of historic steps by the Trump Administration to strengthen America’s steel and aluminum industry. In February, President Trump issued Proclamations 10895 and 10986, which eliminated numerous carve-outs from the Section 232 steel and aluminum tariffs and cracked down on tariff misclassification and duty evasion schemes. These proclamations also directed Commerce, within 90 days, to establish a process for adding steel and aluminum derivative products to the Section 232 tariffs – which Commerce did in May. In June, President Trump issued Proclamation 10947, which increased the tariff rate for steel and aluminum from 25% to 50%, making the tariffs stronger than ever.

Under Commerce’s steel and aluminum product inclusion process, there are three annual windows for the public to submit product inclusion requests. The next window will open in September and will be announced in the Federal Register.

https://www.federalregister.gov/documents/2025/08/19/2025-15819/adoption-and-procedures-of-the-section-232-steel-and-aluminum-tariff-inclusions-process

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Commerce Eases Export Controls on Syria

August 28, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) published a rule easing licensing requirements for civilian exports to Syria.

The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025). EO 14312 declared the United States’ commitment to supporting a Syria that is stable, unified, and at peace with itself and its neighbors. EO 14312 called for the removal of sanctions on Syria, and it also issued waivers that allow for the relaxation of export controls on Syria.

As a result of this rule, U.S.-origin goods, software, and technology that have purely civilian uses (i.e., those classified under BIS’s regulations as “EAR99”), as well as consumer communications devices and certain items related to civil aviation, can generally go to Syria without an export license. In addition, this rule facilitates the approval of licenses for exports to Syria related to telecommunications infrastructure, sanitation, power generation, and civil aviation. All other applications for exports of dual-use items to Syria will be reviewed on a case-by-case basis. BIS will continue to restrict exports when the end-users of items are malign actors, including certain Syrian individuals and entities that remain subject to sanctions.

https://media.bis.gov/press-release/commerce-eases-export-controls-syria

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Department of Commerce Closes Export Controls Loophole for Foreign-Owned Semiconductor Fabs in China

August 29, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) closed a Biden-era loophole that allowed a handful of foreign companies to export semiconductor manufacturing equipment and technology to China license-free. Now these companies will need to obtain licenses to export their technology, putting them on par with their competitors.

The loophole is known as the Validated End-User (VEU) program. In 2023, the Biden Administration expanded the VEU program to allow a select group of foreign semiconductor manufacturers to export most U.S.-origin goods, software, and technology license-free to manufacture semiconductors in China. No U.S.-owned fab has this privilege — and now, following this decision, no foreign-owned fab will have it either.

Former VEU participants will have 120 days following publication of the rule in the Federal Register to apply for and obtain export licenses. Going forward, BIS intends to grant export license applications to allow former VEU participants to operate their existing fabs in China. However, BIS does not intend to grant licenses to expand capacity or upgrade technology at fabs in China.

https://media.bis.gov/press-release/department-commerce-closes-export-controls-loophole-foreign-owned-semiconductor-fabs-china

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U.S. Census Bureau

Foreign Trade Regulations: Clarification of Filing Requirements Regarding In-transit Shipments and other Foreign Trade Regulations Provisions

August 14, 2025: The Census Bureau’s Economic Management Division (EMD) announced the publication of a Final Rule which provides instructions when foreign goods enter the U.S. for consumption or warehousing and are subsequently exported. Additionally, this proposed rule revises several sections, including definitions, mandatory filing requirements, responsibilities of parties to the export transaction, confidentiality, penalty provisions, and voluntary self-disclosures to ensure clarity, accuracy, and consistency throughout the FTR.

The Final Rule can be found in its entirety at Federal Register: Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions

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Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions

August 14, 2025: 90. Fed. Reg. 39112: The Bureau of the Census (Census Bureau) issues this final rule to clarify its regulations governing in-transit shipments from foreign countries through the United States that are subsequently exported to a foreign destination. Specifically, the final rule addresses the identification of the U.S. Principal Party in Interest (USPPI) in scenarios where goods are entered into the United States for consumption or warehousing and subsequently stored in a warehouse or storage facility, admitted into a Foreign Trade Zone (FTZ), or entered into a bonded warehouse before being exported. The rule establishes clear guidelines for different parties involved in export transactions. For customs brokers serving as the USPPI, the regulation notes obtaining client consent to provide customs entry information for Electronic Export Information (EEI) filing is required per customs regulations. Similarly, when a warehouse, storage facility, FTZ, or bonded warehouse operator acts as the USPPI, they are responsible for the EEI based on information they possess or have received from other parties to the export transaction. Additionally, this final rule revises several regulatory sections, including definitions, mandatory filing requirements, responsibilities of parties to the export transaction, confidentiality protocols, penalty provisions, and voluntary self-disclosure processes to ensure greater clarity, accuracy, and consistency throughout the FTR.

https://www.federalregister.gov/documents/2025/08/14/2025-15493/foreign-trade-regulations-ftr-clarification-of-filing-requirements-regarding-in-transit-shipments

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Upcoming Changes to AESDirect for State of Origin

August 15, 2025: This message is a follow-up to the broadcast that was released on August 14, 2025, titled Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-transit Shipments and other FTR Provisions. In the final rule the U.S. Census Bureau changed the name of the “Address of the USPPI” to “Address of Origin”. As a result, the field names under the USPPI section in AESDirect will change to the following:

Current Field Names	New Field Names After Change
Address – Line 1	Address of Origin – Line 1
Address – Line 2	Address of Origin – Line 2
Postal Code	Postal Code of Origin
City	City of Origin
State	State of Origin

The USPPI Address and State of Origin fields are defined identically—both require the filer to report the location where goods begin their journey to the port of export and as a result these fields should match. We are changing the field names to clarify that the USPPI address represents the origin of movement, not the address associated with the USPPI EIN or headquarters address. The updates to the field names will be active in AESDirect on August 19, 2025 after 2:00pm EDT.

Additionally, there will be front-end edits added in AESDirect that will validate matching information for the State of Origin in the USPPI section in Step 2 compared to the State of Origin reported in Step 1. Filers must ensure the full address is updated and reported as the location from which the goods actually begin the journey to the port of export as defined in section 30.6(a)(1)(ii) and 30.6(a)(4) of the FTR.

Note for Template and Profile Users: Filers must edit or delete any existing Shipment Templates or Party Profiles in AESDirect that may include incorrect USPPI Address information. As a reminder, the Shipment Template Manager and Party Profile Manager can be found under the ‘Tools Menu’ located at the top right of your Shipment Manager screen. For instructions on managing Shipment Templates and Party Profiles, please refer to the ACE AESDirect User Guide.

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How to Resolve Common AES Response Messages

August 18, 2025: When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning. It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations.

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

Response Code: 8W1

Narrative: Shipping Weight/Quantity 1 Out of Range

Severity: Verify

Reason: For the reported Schedule B/HTS Number, the Shipping Weight/Quantity (1) ratio is outside of the expected range.

Resolution: For a particular Schedule B/HTS Number reported, the shipping weight divided by the first quantity should fall within a certain parameter based on historical statistical averages for that commodity. Ratios outside this pre-determined parameter might indicate either a keying error or misclassification of the product.

Verify the Shipping Weight, Quantity 1, and Schedule B/HTS Number, correct the shipment and resubmit (if necessary). If the line item is verified correct as reported, no action is necessary.

For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.

LATEST SANCTIONS FINES & PENALTIES

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

Fines and Penalties

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

August 18, 2025: In federal court in Brooklyn, dual U.S. and Russian national Vadim Yermolenko was sentenced by United States District Judge Hector Gonzalez to 30 months in prison for his role in an illicit procurement and money laundering network that sought to acquire ammunition and sensitive dual-use electronics for Russian military and intelligence services. In addition to the term of imprisonment, Judge Gonzalez ordered Yermolenko to pay a forfeiture money judgment of $75,547.00. Yermolenko pleaded guilty in November 2024 to conspiracy to violate the Export Control Reform Act, bank fraud conspiracy, and conspiracy to defraud the United States.

https://www.justice.gov/usao-edny/pr/new-jersey-resident-sentenced-30-months-prison-role-global-export-control-and

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August 21, 2025: At the federal courthouse in Brooklyn, an eight-count indictment was unsealed charging Maxim Larin for his involvement in a scheme to illegally export weapons parts and accessories from the United States to other countries, including Kazakhstan, which serve as transshipment points for materials destined for Russia. The indictment charges Larin with conspiracy to defraud the United States, conspiracy to violate the Export Control Reform Act, conspiracy to violate the Arms Export Control Act, attempted violation of the Arms Export Control Act, smuggling goods from the United States, and submission of false export information. Larin was arrested in Plantation, Florida and made his initial appearance in federal court in Miami. He will be arraigned in the Eastern District of New York at a later date.

https://www.justice.gov/usao-edny/pr/firearms-parts-dealer-arrested-scheme-illegally-export-weapons-parts-and-firearms

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August 28, 2025: 90. Fed. Reg. 41969: On June 8, 2023, in the U.S. District Court for the Southern District of Texas, Imelda Jimenez (“Jimenez”) was convicted of violating 18 U.S.C. 554(a). Specifically, Jimenez was convicted of smuggling firearms from the U.S. to Mexico. As a result of her conviction, the Court sentenced Jimenez to 30 months of imprisonment and two years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Jimenez’s export privileges under the Regulations for a period of seven years from the date of Jimenez’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Jimenez had an interest at the time of her conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16525/in-the-matter-of-imelda-jimenez-434-plantano-brownsville-tx-78521-order-denying-export-privileges

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August 28, 2025: 90. Fed. Reg. 41970: On May 1, 2024, in the U.S. District Court for the Middle District of Florida, Gabriel Daniel Pinnace (“Pinnace”) was convicted of violating 18 U.S.C. 554(a). Specifically, Pinnace was convicted of smuggling firearms from the U.S. to Venezuela. As a result of his conviction, the Court sentenced Pinnace to 72 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Pinnace’s export privileges under the Regulations for a period of 10 years from the date of Pinnace’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Pinnace had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16522/in-the-matter-of-gabriel-daniel-pinnace-inmate-number-77450-510-fci-oakdale-ii-federal-correctional

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August 28, 2025: 90. Fed. Reg. 41978: On May 10, 2021, in the U.S. District Court for the District of Arizona, Francisco Dario Mora (“Mora”) was convicted of (among other crimes) violating 18 U.S.C. 371 and 18 U.S.C. 554(a). Specifically, Mora was convicted of conspiring to smuggle firearms, ammunition and magazines from the United States to Mexico. As a result of his conviction, the Court sentenced Mora to 60 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Mora’s export privileges under the Regulations for a period of 10 years from the date of Mora’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Mora had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16521/in-the-matter-of-francisco-dario-mora-2130-s-7th-avenue-tucson-az-85713-order-denying-export

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August 28, 2025: 90. Fed. Reg. 41981: On February 14, 2024, in the U.S. District Court for the Western District of Texas, (“Gallegos”) was convicted of violating 18 U.S.C. 554 (a) (Smuggling Goods from the United States). Specifically, Gallegos was convicted of smuggling firearms from the United States to Mexico. As a result of her conviction, the court sentenced Gallegos to 60 months in prison and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Gallegos’s export privileges under the Regulations for a period of 10 years from the date of Gallegos’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gallegos had an interest at the time of her conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16533/in-the-matter-of-jasmine-desire-gallegos-inmate-number-61075-509-fpc-bryan-po-box-2149-bryan-tx

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August 28, 2025: 90. Fed. Reg. 41985: On November 30, 2023, in the U.S. District Court for the District of Arizona, Juan Manuel Cervantes-Aceves (“Cervantes-Aceves”) was convicted of violating 18 U.S.C. 554(a). Specifically, Cervantes-Aceves was convicted of smuggling firearms and magazines from the United States to Mexico. As a result of his conviction, the Court sentenced Cervantes-Aceves to four years of probation.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BISI has decided to deny Cervantes-Aceves’s export privileges under the Regulations for a period of 10 years from the date of Cervantes-Aceves’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Cervantes-Aceves had an interest at the time of his conviction

https://www.federalregister.gov/documents/2025/08/28/2025-16528/in-the-matter-of-juan-manuel-cervantes-aceves-5226-e-23rd-street-tucson-az-85042-order-denying

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August 28, 2025: 90. Fed. Reg. 41968: On October 10, 2023, in the U.S. District Court for the District of Arizona, Martina Juanita Gil (“Gil”) was convicted of violating 18 U.S.C. 554(a). Specifically, Gil was convicted of smuggling one thousand (1,000) rounds of .45 caliber ammunition and two thousand (2,000) rounds of 9mm ammunition from the U.S. to Mexico. As a result of her conviction, the Court sentenced Gil to 12 months and one day of imprisonment, with credit for time served, and three years of supervised release.

Based upon BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its Director, and the facts available to BIS, BIS has decided to deny Gil’s export privileges under the Regulations for a period of five years from the date of Gil’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gil had an interest at the time of her conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16516/in-the-matter-of-martina-juanita-gil-2721-e-caldwell-street-phoenix-az-85042-order-denying-export

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August 28, 2025: 90. Fed. Reg. 41972: On November 30, 2023, in the U.S. District Court for the District of Arizona, Guadalupe Gil (“Gil”) was convicted of violating 18 U.S.C. 554(a). Specifically, Gil was convicted of smuggling one thousand (1,000) rounds of .45 caliber ammunition and two thousand (2,000) rounds of 9mm ammunition from the U.S. to Mexico. As a result of his conviction, the Court sentenced Gil to 41 months, with credit for time served, and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Gil’s export privileges under the Regulations for a period of 10 years from the date of Gil’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gil had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16523/in-the-matter-of-guadalupe-gil-2721-e-caldwell-street-phoenix-az-85042-order-denying-export

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August 28, 2025: 90. Fed. Reg. 41973: On November 17, 2023, in the U.S. District Court for the Southern District of California, Cesar David Piz Corona (“Corona”) was convicted of violating 18 U.S.C. 554(a). Specifically, Corona was convicted of smuggling a Springfield Armory XDm 9mm handgun and a Beretta M9 from the United States to Mexico. As a result of his conviction, the Court sentenced Corona to 21 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Corona’s export privileges under the Regulations for a period of five years from the date of Corona’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Corona had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16519/in-the-matter-of-cesar-david-piz-corona-830-n-lamb-blvd-space-3-las-vegas-nv-89110-order-denying

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August 28, 2025: 90. Fed. Reg. 41977: On June 11, 2024, in the U.S. District Court for the District Southern of Texas, Jose Guadalupe Mejia (“Mejia”) was convicted of violating 18 U.S.C. 554(a). Specifically, Mejia was convicted of attempting to export 701 rounds of assorted ammunition from the United States to Mexico, without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the Court sentenced Mejia to 46 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Mejia’s export privileges under the Regulations for a period of 10 years from the date of Mejia’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Mejia had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16527/in-the-matter-of-jose-guadalupe-mejia-inmate-number-37825-510-fci-beaumont-low-federal-correctional

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August 29, 2025: 90. Fed. Reg. 41979: On December 5, 2023, in the U.S. District Court for the Southern District of Georgia, Prince Bediako (“Bediako”) was convicted of violating 18 U.S.C. 554. Specifically, Bediako was convicted of smuggling fraudulently obtained vehicles from the United States to Ghana. As a result of his conviction, the Court sentenced Bediako to 28 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Bediako’s export privileges under the Regulations for a period of seven years from the date of Bediako’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Bediako had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16535/in-the-matter-of-prince-bediako-3790-longview-drive-douglasville-ga-30135-1370-order-denying-export

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August 28, 2025: 90. Fed. Reg. 41980: On July 12, 2024, in the U.S. District Court for the Northern District of Georgia, Kamir Armando Brown Blanchard (“Blanchard”) was convicted of violating 18 U.S.C. 554. Specifically, Blanchard was convicted of unlawfully exporting firearms from the U.S. to Panama. As a result of his conviction, the Court sentenced Blanchard to 36 months of imprisonment and one year of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Blanchard’s export privileges under the Regulations for a period of 10 years from the date of Blanchard’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Blanchard had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16511/in-the-matter-of-kamir-armando-brown-blanchard-register-number-25223-510-fci-atlanta-po-box-150160

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August 28, 2025: 90. Fed. Reg. 41972: On August 31, 2023, in the U.S. District Court for the Southern District of Texas, Pedro Cruz Almeida, Jr. (“Almeida”) was convicted of violating 18 U.S.C. 554(a) (Smuggling Goods from the United States). Specifically, Almeida was convicted of smuggling nine hundred (900) rounds of Lake City .50 caliber tracer-equipped linked ammunition, from the United States to Mexico, without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the court sentenced him to 50 months in prison and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Almeida’s export privileges under the Regulations for a period of 10 years from the date of Almeida’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Almeida had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16531/in-the-matter-of-pedro-cruz-almeida-jr-inmate-number-43804-510-fci-beaumont-po-box-26020-bryan-tx

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August 28, 2025: 90. Fed. Reg. 41974: On July 17, 2024, in the U.S. District Court for the District Southern of New York, Maxim Marchenko (“Marchenko”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Marchenko was convicted of unlawfully causing companies in the United States to export OLED micro-displays from the United States to Russia. Marchenko was also convicted of conspiracy to commit money laundering. As a result of his convictions, the Court sentenced Marchenko to 36 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Marchenko’s export privileges under the Regulations for a period of ten (10) years from the date of Marchenko’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Marchenko had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16529/in-the-matter-of-maxim-marchenko-inmate-number-78093-510-fci-allenwood-low-federal-correctional

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August 28, 2025: 90. Fed. Reg. 41978: On April 18, 2024, in the U.S. District Court for the Southern District of Texas, Jessica Alvarado (“Alvarado”) was convicted of violating 18 U.S.C. 554(a). Specifically, Alvarado was convicted of smuggling thirty-three 7.62×39 caliber rifles, three 5.56 caliber rifles, one Ruger .22 caliber carbine rifle, two .45 caliber pistols, and thirty-nine ammunition magazines from the U.S. to Mexico, without a license or written approval from the U.S. Department of Commerce. As a result of her conviction, the Court sentenced Alvarado to 46 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Alvarado’s export privileges under the Regulations for a period of 10 years from the date of Alvarado’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Alvarado had an interest at the time of her conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16526/in-the-matter-of-jessica-alvarado-inmate-number-42634-510-fpc-bryan-federal-prison-camp-po-box-2149

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August 28, 2025: 90. Fed. Reg. 41982: On May 16, 2024, in the U.S. District Court for the Southern District of Texas, Damian Alejandro Vidal (“Vidal”) was convicted of violating 18 U.S.C. 554(a). Specifically, Vidal was convicted of smuggling one Sig Sauer, model 1911 .45 caliber handgun and one Glock, model 19, 9mm handgun, from the U.S. to Mexico, without having first obtained the required licenses. As a result of his conviction, the Court sentenced Vidal to 40 months in prison and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Vidal’s export privileges under the Regulations for a period of eight years from the date of Vidal’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Vidal had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16520/in-the-matter-of-damian-alejandro-vidal-inmate-number-93487-510-fmc-fort-worth-federal-medical

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August 28, 2025: 90. Fed. Reg. 41984: On August 6, 2024, in the U.S. District Court for the Southern District of New York, Miguel Barrera (“Barrera”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States) and 18 U.S.C. 1956(a)(2) (Money Laundering). With respect to the smuggling count, specifically, Barrera was convicted of concealing and exporting from the United States, and attempting to export from the United States, firearms and firearms components, knowing that the export of such firearms and firearms components was contrary to law. As a result of his conviction, the Court sentenced Barrera to 80 months of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Barrera’s export privileges under the Regulations for a period of 10 years from the date of Barrera’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Barrera had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16534/in-the-matter-of-miguel-barrera-inmate-number-10606-506-fci-fort-dix-federal-correctional

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August 28, 2025: 90. Fed. Reg. 41971: On April 30, 2024, in the U.S. District Court for the Eastern District of New York, Vladimir Kuznetsov (“Kuznetsov”) was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778) (“AECA”). Specifically, Kuznetsov was convicted of knowingly and willfully exporting and attempting to export from the United States to Russia without obtaining required U.S. government authorization rifle parts and accessories designated as defense articles on the United States Munitions List, to wit: one Accuracy International AICS AX MK II rifle chassis, one “H-S Precision” aluminum rifle stock, one “Kinetic Research Group” savage 180-Alpha rifle chassis, one Dakota bolt shroud, one Timney Sportsman trigger assembly, multiple firearm magzines, and other firearms accessories. As a result of his conviction, the Court sentenced Kuznetsov to 46 months in prison and two years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Kuznetsov’s export privileges under the Regulations for a period of 10 years from the date of Kuznetsov’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Kuznetsov had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16530/in-the-matter-of-vladimir-kuznetsov-inmate-number-91806-053-fci-allenwood-low-federal-correctional

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August 28, 2025: 90. Fed. Reg. 41975: On March 29, 2024, in the U.S. District Court for the Northern District of California, Fares Abdo Al Eyani (“Al Eyani”) was convicted of violating 18 U.S.C. 371 and Section 38 of the Arms Export Control Act (22 U.S.C. 2778) (“AECA”). Specifically, Al Eyani was convicted of conspiring and attempting to illegally export or cause to be exported defense articles to the Sultanate of Oman, without an export license, and in knowing and willful violation of the AECA and the International Traffic in Arms Regulations. As a result of his conviction, the Court sentenced Al Eyani to 12 months and one day of imprisonment and three years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Al Eyani’s export privileges under the Regulations for a period of ten (10) years from the date of Al Eyani’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Al Eyani had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16541/in-the-matter-of-fares-abdo-al-eyani-3838-turquoise-way-unit-415-oakland-ca-94609-order-denying

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August 28, 2025: 90. Fed. Reg. 41983: On June 21, 2024, in the U.S. District Court for the Middle District of Florida, Chrissie Fier Williams (“Williams”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Willaims was convicted of attempting to export or send firearms, firearms parts and components, and ammunition from the United States to Trinidad & Tobago without required authorization. As a result of his conviction, the Court sentenced Williams to 37 months of imprisonment and two years of supervised release.

Based on BIS’ review of the record and consultations with BIS’ Office of Exporter Services, including its director, and the facts available to BIS, BIS has decided to deny Williams’s export privileges under the Regulations for a period of 10 years from the date of Williams’s conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Williams had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/08/28/2025-16532/in-the-matter-of-chrissie-fier-williams-inmate-number-87415-510-fci-allenwood-low-federal

Sanctions

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

August 22, 2025: 90 Fed. Reg. 40458: Pursuant to section 38(g)(4) of the AECA and section 127.7(b) and (c)(1) of the ITAR, the following persons, having been convicted in a U.S. District Court, are denied export privileges and are statutorily debarred as of the date of this notice (Name; Date of Judgment; Judicial District; Case No.; Month/Year of Birth):

Aldalawi, Rawnd Khaleel; January 11, 2019; Western District of Washington; 2:18-cr-00025; April 1988;
Chan, Lionel; June 1, 2021; District of Massachusetts; 1:19-cr-10064; August 1983;
Cox, Michael; May 27, 2021; Western District of Pennsylvania; 2:18-cr-00050; May 1975;
Duroseau, Jacques Yves Sebastien; March 2, 2021; Eastern District of North Carolina; 4:20-cr-3; May 1986;
Garza-Solis, Jacobo Javier; November 4, 2020; Southern District of Texas; 7:17-cr-00360; December 1996;
Issa, Jean Youssef; December 20, 2023; Northern District of Ohio; 1:16-cr-00102; June 1974;
Koyshman, Josef; February 7, 2020; District of Columbia; 1:19-cr-00267; June 1967;
Kuznetsov, Vladimir; May 1, 2024; Eastern District of New York; 1:21-cr-00099; October 1961;
Man, Cho Yan Nathan; a.k.a Nathan Man; May 19, 2020; District of Columbia; 1:19-cr-00218; December 1985;
Palomares, Jr., Rafael; May 13, 2021; District of Arizona; 2:19-cr-00089; July 1989;
Radzi, Muhammad Mohd; June 1, 2021; District of Massachusetts; 1:19-cr-10064; June 1993;
Rhoomes, Jermaine Craig; a.k.a. Rhoomas, Jermain; a.k.a. Rhoomas, Jermaine Craig; a.k.a. Rhooms, Jermaine; a.k.a. Hall, Craig; a.k.a. Hall, Kreig; a.k.a. Cow; February 5, 2020; Middle District of Florida; 8:19-cr-00078; April 1973;
Rincon-Avilez, Gardenia Marlene; December 16, 2024; District of Arizona; 4:18-cr-01141; July 1986;
Schultz, Korbein; April 28, 2025; Middle District of Tennessee; 3:24-cr-00056; May 1999;
Senbol, Yuksel; October 31, 2024; Middle District of Florida, 8:23-cr-00384; May 1987;
Shifrin, Elena; a.k.a Belov, Alexander; a.k.a Ivanov, Lena; a.k.a Gohkman, Elena; a.k.a. Elena Leonidovna Shifrin; July 23, 2024; Central District of California; 2:21-cr-00259; February 1962; and
Stashchyshyn, Michael; July 20, 2021; Western District of Pennsylvania; 2:18-cr-00050; July 1962.

At the end of the three-year period following the date of this notice, the above-named persons remain debarred unless a request for reinstatement from statutory debarment is approved by the Department of State.

https://www.federalregister.gov/documents/2025/08/19/2025-15725/bureau-of-political-military-affairs-statutory-debarment-under-the-arms-export-control-act-and-the

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

August 6, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three high-ranking members and one prominent associate of the Mexico-based Cartel del Noreste (CDN), formerly known as Los Zetas. CDN, one of the most violent drug trafficking organizations in Mexico, is a U.S.-designated Foreign Terrorist Organization (FTO) that exerts significant influence over the U.S.-Mexico border, specifically the Laredo, Texas point of entry. CDN’s influence in the Mexican border cities of Nuevo Laredo, Tamaulipas and Piedras Negras, Coahuila, has affected communities on both sides of the border, and the cartel’s role in fentanyl trafficking and human smuggling into the United States puts American lives at risk. The individuals being designated play key roles in aiding CDN’s horrific crimes, including assassinations, beheadings, drug trafficking, extortion, and money laundering.

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

Esqueda Nieto, Francisco Daniel of Mexico;
Hernandez Medrano, Ricardo of Mexico;
Rodriguez Garcia, Abdon Federico of Mexico; and
Romero Sanchez, Antonio of Mexico.

https://ofac.treasury.gov/recent-actions/20250806 and

https://home.treasury.gov/news/press-releases/sb0219

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August 7, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 18 entities and individuals that play pivotal roles in the Iranian regime’s efforts to generate revenue and circumvent U.S. sanctions. Facing severe financial constraints due to international isolation, Iran has engineered sophisticated banking schemes and alternate payment messaging systems specifically designed to bypass sanctions and protect its ability to collect export revenues, particularly from illicit petroleum sales. These systems also enable the regime’s continued funding of its proxies and oppression of the Iranian people. Additionally, financial and information technology firms designated have provided the regime with advanced surveillance technologies that Iran’s security services deploy to restrict internet access and to target women who violate the regime’s mandatory hijab restrictions.

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

Berjisian, Adel of Iran;
Birang, Ali Morteza of Iran;
Fatahinojokambari, Alireza of Iran;
Javanmardi, Shahab of Iran;
Nouri, Hadi of Iran;
Sajjadi, Seyyed Mahmoud Reza of Iran; and
Shafipour, Mohammad of Iran.

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

Arian Pasargad Communications and Information Technology Ecosystem Development Company of Iran;
Arian Pasargad Communications and Information Technology Infrastructure Company of Iran;
Arman Kish Data Communications and Information Technology Company of Iran;
Arvand Arian Pasargad Communications and Information Technology Payment Company of Iran;
Cyrus Offshore Bank of Iran;
Pasargad Arian Information and Communication Technology Company of Iran;
Pasagrad Electronic Payment Services Company of Iran;
Qeshim Arian Datis Sofrtware Company of Iran;
Rashid Samaneh Electronic Processing Company of Iran;
Runc Exchange Systems Company of Iran; and
Sherkat-E Barid Fanavar Arian of Iran.

https://ofac.treasury.gov/recent-actions/20250807 and

https://ofac.treasury.gov/recent-actions/20250807

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August 11, 2025: The Department of State designated The Balochistan Liberation Army (BLA) and its alias, The Majeed Brigade, as a Foreign Terrorist Organization (FTO), and added the Majeed Brigade as an alias to BLA’s previous Specially Designated Global Terrorist (SDGT) designation.

The following changes have been made to OFAC’s SDN List:

Balochistan Liberation Army of Pakistan.

https://www.state.gov/releases/office-of-the-spokesperson/2025/08/terrorist-designation-of-the-majeed-brigade/ and

https://ofac.treasury.gov/recent-actions/20250811

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August 12, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on entities linked to armed group violence and the sale of critical minerals in the Democratic Republic of the Congo (DRC). Eastern DRC has experienced thousands of civilian deaths and a mass displacement crisis due to ongoing instability, which has been exacerbated recently by the Rwanda-backed March 23 Movement’s (M23) territorial control and reprisal attacks from DRC-aligned militias. M23, a U.S.- and United Nations-designated armed group, has rapidly expanded its territorial control in eastern DRC and is responsible for human rights abuses.

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

Coalition of Congolese Patriotic Resistance-Force De Frappe of the Democratic Republic of the Congo;
Cooperative Des Artisanaux Miniers Du Congo of the Democratic Republic of the Congo;
East Rise Corporation Limited of the Democratic Republic of the Congo; and
Star Dragon Corporation Limited of the Democratic Republic of the Congo.

https://ofac.treasury.gov/recent-actions/20250812 and

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

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August 13, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 125, “Authorizing Transactions Related to Meetings Between the Government of the United States of America and the Government of the Russian Federation in Alaska.”

GENERAL LICENSE NO. 125: “Authorizing Transactions Related to Meetings Between the Government of the United States of America and the Government of the Russian Federation in Alaska”

All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), or the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR), that are ordinarily incident and necessary to the attendance at or support of meetings in the State of Alaska between the Government of the United States of America and the Government of the Russian Federation are authorized through 12:01 a.m. eastern daylight time, August 20, 2025.

https://ofac.treasury.gov/recent-actions/20250813_33 and

https://ofac.treasury.gov/media/934566/download?inline

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August 13, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four Mexican individuals and 13 Mexican companies linked to timeshare fraud led by the Cartel de Jalisco Nueva Generacion (CJNG). These individuals and companies are based in or near Puerto Vallarta, a popular tourist destination that also serves as a strategic stronghold for CJNG. A brutally violent cartel, CJNG is a U.S.-designated Foreign Terrorist Organization (FTO) that is increasingly supplementing its drug trafficking proceeds with alternative revenue streams such as timeshare fraud and fuel theft.

The following individual has been added to OFAC’s SDN List:

Ibarra Biaz Jr, Michael of Mexico.

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

Akali Realtors of Mexico;
Centro Mediador De La Costa, S.A. DE C.V. of Mexico;
Consultorias Profesionales Almida, S.A. of Mexico;
Corporative Costa Norte, S.A. DE C.V., of Mexico;
Corporativo Integral De La Costa, S.A. DE C.V. of Mexico;
Fishing Are US, S. DE R.L. DE C.V. of Mexico;
Inmobiliaria Integral Del Puerto, S.A. DE C.V. of Mexico;
KVY Bucerias, S.A. DE C.V. of Mexico;
Laminado Profesional Automotriz Elte, S.A. DE C.V. of Mexico;
Santamaria Cruise, S. DE R.L. DE C.V. of Mexico;
Servicios Inmobiliarios Ibadi, S.A. DE C.V. of Mexico;
Sunmex Travel, S. DE C.V. of Mexico; and
TTR Go, S.A. of Mexico.

https://ofac.treasury.gov/recent-actions/20250813

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August 14, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) re-designated the cryptocurrency exchange Garantex Europe OU (Garantex), which has directly facilitated notorious ransomware actors and other cybercriminals by processing over $100 million in transactions linked to illicit activities since 2019. OFAC also designated Garantex’s successor, Grinex, and taking action against three executives of Garantex and six associated companies in Russia and the Kyrgyz Republic that have supported the exchange’s involvement in malicious cyber activities.

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

Karavatsky, Pavel of Russia;
Mendeleev, Sergey of Russia; and
Mira Serda, Aleksandr Khoseluisovich of Russia.

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

A7 Agent Limited Liability Company of Russia;
A7 Limited Liability Company of Russia;
A71 Limited Liability Company of Russia;
Exved of Russia;
Grinex of Russia;
Independent Decentralized Finance Smartbank and Ecosystem of Russia; and
Old Vector LLC of Russia.

https://home.treasury.gov/news/press-releases/sb0225 and

https://ofac.treasury.gov/recent-actions/20250814

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August 14, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two notorious Mexican cartels—Carteles Unidos (a.k.a. “United Cartels”) and Los Viagras—and seven affiliated individuals linked to terrorism, drug trafficking, and extortion in Mexico’s agricultural sector. Treasury’s action, taken pursuant to counternarcotics and counterterrorism authorities, further implements President Trump’s directive to eliminate completely cartels and transnational criminal organizations threatening the American people.

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

Barragan Chavez, Luis Enrique of Mexico;
Flores, Heladio Cisneros of Mexico;
Alvarez, Juan Jose Farias of Mexico;
Fernandez, Magallon of Mexico;
Orozco Cabada, Edgar Valeriano of Mexico;
Sepulveda Arellano, Cesar Alejandro of Mexico; and
Sierra Santana, Nicolas.

https://ofac.treasury.gov/recent-actions/20250814 and

https://home.treasury.gov/news/press-releases/sb0224

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August 18, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Costa Rican nationals, as well as two Costa Rica-based entities, for their involvement in narcotics trafficking and money laundering. A key global cocaine transshipment hub, Costa Rica has become an increasingly significant waypoint for criminal groups trafficking cocaine into the United States. According to the Drug Enforcement Administration (DEA), cocaine continues to pose a serious threat to the public, causing over 22,000 overdose deaths in the United States in the 12-month period ending in October 2024.

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

Arias Monge, Alejandro of Cota Rica;
Gamboa Sanchez, Celso Manuel of Costa Rica;
James Wilson, Alejandro Antonio of Costa Rica; and
Lopez Vega, Edwin Danney of Costa Rica.

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

Bufete Celso Gamboa and Asociados of Costa Rica; and
Limon Black Star FC of Costa Rica.

https://ofac.treasury.gov/recent-actions/20250818 and

https://home.treasury.gov/news/press-releases/sb0227

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August 20, 2025: The United States sanctioned four individuals, currently serving on the International Criminal Court (ICC). The Department of State’s designations are made pursuant to Executive Order (E.O.) 14203, which authorizes sanctions on foreign persons engaged in certain malign efforts by the ICC and aims to impose tangible and significant consequences on those directly engaged in the ICC’s transgressions against the United States and Israel.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued International Criminal Court-related General License 9, “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on August 20, 2025.”

GENERAL LICENSE NO. 9: “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on August 20, 2025”

(a) All transactions prohibited by the International Criminal Court-Related Sanctions Regulations (ICCSR), 31 CFR part 528, that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern daylight time, September 19, 2025, provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States, in accordance with the ICCSR:

(1) Nicolas Yann Guillou;

(2) Nazhat Shameem Khan;

(3) Mame Mandiaye Niang;

(4) Kimberly Prost; or

(5) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

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

Guillou, Nicolas Yann of France;
Khan, Nazhat Shameen of Fiji;
Niang, Mame Mandiaye of Senegal; and
Prost, Kimberly of Canada.

https://ofac.treasury.gov/recent-actions/20250820

https://ofac.treasury.gov/media/934581/download?inline

https://www.state.gov/releases/office-of-the-spokesperson/2025/08/imposing-further-sanctions-in-response-to-the-iccs-ongoing-threat-to-americans-and-israelis/

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August 21, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) further disrupted Iran’s oil exports by imposing sanctions on Greek national Antonios Margaritis, his network of companies, and nearly a dozen vessels involved in Iran’s shadow fleet. Margaritis has leveraged his decades of experience in the shipping industry to illicitly facilitate the transportation and sale of Iranian petroleum. Several other vessels and operators are also being designated for their role facilitating Iranian oil exports, which generates revenue that contributes to Iran’s advanced weapons programs.

The following individual has been added to OFAC’s SDN List:

Margatis, Antonios of Greece.

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

Ares Shipping Limited of China;
Comford Management S.A. of the Marshall Islands;
Cristobal Marine Corp of the Marshall Islands;
Hong Kong Hangshun Shipping Limited of China;
Marant Shipping and Trading S.A. of Greece;
Ozarka Shipping – FZCO of the United Arab Emirates;
Qingdao Port Haiye Dongjiakou Oil of China;
Regal Liberty Limited of China;
Square Tanker Management Ltd. of the Marshall Islands;
U Beacon Shipping Co., Limited of China;
United Chartering S.A. of the Marshall Islands; and
Yangshan Shengang International Petroleum Storage and Transportation Co., Ltd of China.

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

Adeline G 3E3513) Crude Oil Tanker Panama flag; MMSI 352002297 (vessel);
Ares (E5U3903) Crude Oil Tanker Cook Islands flag; MMSI 518100992 (vessel);
Giant (a.k.a. MACHO QUEEN) (VRUF3) Crude Oil Tanker Hong Kong flag; MSI 477722100 (vessel);
Katsuya (C5J502) Oil Products Tanker Gambia flag; MMSI 629009490 (vessel);
Kongm (3E5132) Crude Oil Tanker Panama flag; MMSI 353529000 (vessel);
Lafit (S9A3169) Crude Oil Tanker Sao Tome & Principe flag; MMSI 668116369 (vessel);
Sondos (V2YL4) Chemical/Oil Tanker Antigua and Barbuda flag; MMSI 305263000 (vessel); and
Victory Ari (V2YR4) Chemical/Oil Tanker Antigua and Barbuda flag; MMSI 305049000 (vessel).

https://ofac.treasury.gov/recent-actions/20250821

https://home.treasury.gov/news/press-releases/sb0229

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August 25, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Syrian Sanctions Regulations to remove them from the Code of Federal Regulations, consistent with Executive Order 14312 of June 30, 2025, “Providing for the Revocation of Syria Sanctions.” This regulatory amendment is currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on August 26, 2025.

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August 27, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Vitaliy Sergeyevich Andreyev, Kim Ung Sun, Shenyang Geumpungri Network Technology Co., Ltd, and Korea Sinjin Trading Corporation for their roles in a fraudulent information technology (IT) worker scheme orchestrated by the Democratic People’s Republic of Korea (DPRK) government.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 104A, “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068.”

GENERAL LICENSE NO. 104A: “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068”

(a) All transactions prohibited by the determination of February 8, 2024 made pursuant to section 1(a)(i)(B) of Executive Order (E.O.) 14068 (“Prohibitions Related to Imports of Certain Categories of Diamonds”) that are ordinarily incident and necessary to the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of the following categories of diamonds are authorized through 12:01 a.m. eastern daylight time, September 1, 2026, provided that the diamonds were physically located outside of the Russian Federation before, and were not exported or re-exported from the Russian Federation since:

(1) March 1, 2024 for non-industrial diamonds with a weight of 1.0 carat or greater; or

(2) September 1, 2024 for non-industrial diamonds with a weight of 0.5 carats or greater.

https://ofac.treasury.gov/media/934591/download?inline

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

Andreyev, Vitaly Sergeyevich of Russia; and
Kim, Ung Sun of North Korea.

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

Korea Sinjin Trading Corporation of North Korea; and
Shenyang Geumpungri Network Technology Co., Ltd of China.

https://ofac.treasury.gov/recent-actions/20250827

https://home.treasury.gov/news/press-releases/sb0230

https://ofac.treasury.gov/media/934591/download?inline

AUGUST 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

JULY 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through July 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

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

REGULATORY UPDATES

President

PROMOTING THE EXPORT OF THE AMERICAN AI TECHNOLOGY STACK

July 23, 2025: By the authority vested in the President by the Constitution and the laws of the United States of America, including section 301 of title 3, United States Code, it is hereby ordered:

Section 1. Purpose. Artificial intelligence (AI) is a foundational technology that will define the future of economic growth, national security, and global competitiveness for decades to come. The United States must not only lead in developing general-purpose and frontier AI capabilities, but also ensure that American AI technologies, standards, and governance models are adopted worldwide to strengthen relationships with our allies and secure our continued technological dominance. This order establishes a coordinated national effort to support the American AI industry by promoting the export of full-stack American AI technology packages.

Sec. 2. Policy. It is the policy of the United States to preserve and extend American leadership in AI and decrease international dependence on AI technologies developed by our adversaries by supporting the global deployment of United States-origin AI technologies.

Sec. 3. Establishment of the American AI Exports Program. (a) Within 90 days of the date of this order, the Secretary of Commerce shall, in consultation with the Secretary of State and the Director of the Office of Science and Technology Policy (OSTP), establish and implement the American AI Exports Program (Program) to support the development and deployment of United States full-stack AI export packages.

(b) The Secretary of Commerce shall issue a public call for proposals from industry-led consortia for inclusion in the Program. The public call shall require that each proposal must:

(i) include a full-stack AI technology package, which encompasses:

(A) AI-optimized computer hardware (e.g., chips, servers, and accelerators), data center storage, cloud services, and networking, as well as a description of whether and to what extent such items are manufactured in the United States;

(B) data pipelines and labeling systems;

(D) measures to ensure the security and cybersecurity of AI models and systems; and

(E) AI applications for specific use cases (e.g., software engineering, education, healthcare, agriculture, or transportation);

(ii) identify specific target countries or regional blocs for export engagement;

(iii) describe a business and operational model to explain, at a high level, which entities will build, own, and operate data centers and associated infrastructure;

(iv) detail requested Federal incentives and support mechanisms; and

(v) comply with all relevant United States export control regimes, outbound investment regulations, and end-user policies, including chapter 58 of title 50, United States Code, and relevant guidance from the Bureau of Industry and Security within the Department of Commerce.

(c) The Department of Commerce shall require proposals to be submitted no later than 90 days after the public call for proposals is issued, and shall consider proposals on a rolling basis for inclusion in the Program.

(d) The Secretary of Commerce shall, in consultation with the Secretary of State, the Secretary of Defense, the Secretary of Energy, and the Director of OSTP, evaluate submitted proposals for inclusion under the Program. Proposals selected by the Secretary of Commerce, in consultation with the Secretary of State, the Secretary of Defense, the Secretary of Energy, and the Director of OSTP, will be designated as priority AI export packages and will be supported through priority access to the tools identified in section 4 of this order, as consistent with applicable law.

Sec. 4. Mobilization of Federal Financing Tools. (a) The Economic Diplomacy Action Group (EDAG), established in the Presidential Memorandum of June 21, 2024, chaired by the Secretary of State, in consultation with the Secretary of Commerce and the United States Trade Representative, and as described in section 708 of the Championing American Business Through Diplomacy Act of 2019 (Title VII of Division J of Public Law 116-94) (CABDA), shall coordinate mobilization of Federal financing tools in support of priority AI export packages.

(b) I delegate to the Administrator of the Small Business Administration and the Director of OSTP the authority under section 708(c)(3) of CABDA to appoint senior officials from their respective executive departments and agencies to serve as members of the EDAG.

(i) developing and executing a unified Federal Government strategy to promote the export of American AI technologies and standards;

(ii) aligning technical, financial, and diplomatic resources to accelerate deployment of priority AI export packages under the Program;

(iii) coordinating United States participation in multilateral initiatives and country-specific partnerships for AI deployment and export promotion;

(iv) supporting partner countries in fostering pro‑innovation regulatory, data, and infrastructure environments conducive to the deployment of American AI systems;

(v) analyzing market access, including technical barriers to trade and regulatory measures that may impede the competitiveness of United States offerings; and

(vi) coordinating with the Small Business Administration’s Office of Investment and Innovation to facilitate, to the extent permitted under applicable law, investment in United States small businesses to the development of American AI technologies and the manufacture of AI infrastructure, hardware, and systems.

(d) Members of the EDAG shall deploy, to the maximum extent permitted by law, available Federal tools to support the priority export packages selected for participation in the Program, including direct loans and loan guarantees (12  U.S.C. 635); equity investments, co-financing, political risk insurance, and credit guarantees (22  U.S.C. 9621); and technical assistance and feasibility studies (22 U.S.C. 2421(b)).

Sec. 5. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:

(i) the authority granted by law to an executive department or agency, or the head thereof; or

(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.

(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.

(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

(d) The costs for publication of this order shall be borne by the Department of Commerce.

https://www.whitehouse.gov/presidential-actions/2025/07/promoting-the-export-of-the-american-ai-technology-stack/

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SUSPENDING DUTY-FREE DE MINIMIS TREATMENT FOR ALL COUNTRIES

July 30, 2025: By the authority vested in the President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), and section 301 of title 3, United States Code, it is hereby ordered:

Section 1. Background. In Executive Order 14193 of February 1, 2025 (Imposing Duties To Address the Flow of Illicit Drugs Across Our Northern Border), I declared a national emergency regarding the unusual and extraordinary threat to the safety and security of Americans, including the public health crisis caused by fentanyl and other illicit drugs and the failure of Canada to do more to arrest, seize, detain, or otherwise intercept drug trafficking organizations, other drug and human traffickers, criminals at large, and illicit drugs. In that order, I determined that it was necessary and appropriate to, among other things, suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for articles described in section 2(a) and section 2(b) of that order. In Executive Order 14226 of March 2, 2025 (Amendment to Duties To Address the Flow of Illicit Drugs Across Our Northern Border), I paused the suspension of duty-free de minimis treatment on such articles until I received a notification from the Secretary of Commerce (Secretary) that adequate systems are in place to fully and expeditiously process and collect duties for such articles that would otherwise be eligible for duty-free de minimis treatment.

In Executive Order 14194 of February 1, 2025 (Imposing Duties To Address the Situation at Our Southern Border), I declared a national emergency regarding the unusual and extraordinary threat to the safety and security of Americans, including the public health crisis caused by fentanyl and other illicit drugs and the failure of Mexico to do more to arrest, seize, detain, or otherwise intercept drug trafficking organizations, other drug and human traffickers, criminals at large, and illicit drugs. In that order, I determined that it was necessary and appropriate to, among other things, suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for articles described in section 2(a) of that order. In Executive Order 14227 of March 2, 2025 (Amendment to Duties To Address the Situation at Our Southern Border), I paused the suspension of duty-free de minimis treatment on such articles until I received a notification from the Secretary that adequate systems are in place to fully and expeditiously process and collect duties for such articles that would otherwise be eligible for duty-free de minimis treatment.

In Executive Order 14195 of February 1, 2025 (Imposing Duties To Address the Synthetic Opioid Supply Chain in the People’s Republic of China), I declared a national emergency regarding the unusual and extraordinary threat from the failure of the Government of the People’s Republic of China (PRC) to arrest, seize, detain, or otherwise intercept chemical precursor suppliers, money launderers, other transnational criminal organizations, criminals at large, and illicit drugs. In that order, I determined that it was necessary and appropriate to, among other things, suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for articles described in section 2(a) of that order. In Executive Order 14200 of February 5, 2025 (Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China), I paused the suspension of duty-free de minimis treatment for articles described in section 2(a) of Executive Order 14195 until I received a notification from the Secretary that adequate systems are in place to fully and expeditiously process and collect duties for such articles that would otherwise be eligible for duty-free de minimis treatment.

The President subsequently received notification from the Secretary that adequate systems have been established to process and collect duties for articles of the PRC and Hong Kong that would otherwise be eligible for duty-free de minimis treatment, and in Executive Order 14256 of April 2, 2025 (Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports), I suspended duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for products of the PRC and Hong Kong described in section 2(a) of Executive Order 14195, as amended by Executive Order 14228 (Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China). In addition, I instructed the Secretary to submit a report regarding the impact of Executive Order 14256 on American industries, consumers, and supply chains and to make recommendations for further action as he deems necessary.

In Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits), I declared a national emergency with respect to underlying conditions indicated by the large and persistent annual U.S. goods trade deficits. I also provided that duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) would remain available for products described in section 3(a) of that order until I received a notification by the Secretary that adequate systems are in place to fully and expeditiously process and collect duties applicable for articles otherwise eligible for duty-free de minimis treatment.

The Secretary has notified me that adequate systems are now in place to fully and expeditiously process and collect duties for articles otherwise eligible for duty-free de minimis treatment on a global basis, including for products described in section 2(a) and section 2(b) of Executive Order 14193, section 2(a) of Executive Order 14194, and section 3(a) of Executive Order 14257.

The President determines that it is still necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) in the manner and for the articles described below to deal with the unusual and extraordinary threats, which have their source in whole or substantial part outside the United States, to the national security, foreign policy, and economy of the United States.

The President determines that it is necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for certain Canadian goods to deal with the emergency declared in Executive Order 14193, as amended. In my judgment, this suspension is necessary and appropriate to ensure that the tariffs imposed by Executive Order 14193, as amended, are effective in addressing the emergency declared in Executive Order 14193 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14193 is not undermined. For example, many shippers go to great lengths to evade law enforcement and hide illicit substances in imports that go through international commerce. These shippers conceal the true contents of shipments sent to the United States through deceptive shipping practices. Some of the techniques employed by these shippers to conceal the true contents of the shipments, the identity of the distributors, and the country of origin of the imports include the use of re-shippers in the United States, false invoices, fraudulent postage, and deceptive packaging. The risks of evasion, deception, and illicit-drug importation are particularly high for low-value articles that have been eligible for duty-free de minimis treatment.

The President determines that it is necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for certain Mexican goods to deal with the emergency declared in Executive Order 14194, as amended. In my judgment, and for substantially similar reasons as above, this suspension is necessary and appropriate to ensure that the tariffs imposed by Executive Order 14194, as amended, are effective in addressing the emergency declared in Executive Order 14194 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14194 is not undermined.

Independently, and after considering information newly provided by the Secretary, among other things, the President determines that it is still necessary and appropriate to continue to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for certain goods of the PRC and Hong Kong to deal with the emergency declared in Executive Order 14195, as amended. In my judgment, and for substantially similar reasons as above, this suspension is still necessary and appropriate to ensure that the tariffs imposed by Executive Order 14195, as amended, are effective in addressing the emergency declared in Executive Order 14195 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14195 is not undermined.

Also independently, The President determines that it is necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) on a global basis to deal with the emergency declared in Executive Order 14257, as amended. In my judgment, this suspension is necessary and appropriate to ensure that the tariffs imposed by Executive Order 14257, as amended, are not evaded and are effective in addressing the emergency declared in Executive Order 14257 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14257 is not undermined.

Each of the Presidents determinations to suspend or continue to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) are independent from the other. And each determination is made only for the purpose to deal with the respective emergency and not for the purpose of dealing with another emergency.

Sec. 2. Suspension of Duty-Free de minimis Treatment. (a) The duty-free de minimis exemption provided under 19 U.S.C. 1321(a)(2)(C) shall no longer apply to any shipment of articles not covered by 50 U.S.C. 1702(b), regardless of value, country of origin, mode of transportation, or method of entry. Accordingly, all such shipments, except those sent through the international postal network, shall be subject to all applicable duties, taxes, fees, exactions, and charges. International postal shipments not covered by 50 U.S.C. 1702(b) shall be subject to the duty rates described in section 3 of this order. Entry for all shipments that — prior to the effective date of this order — qualified for the de minimis exemption, except for shipments sent through the international postal network, shall be filed using an appropriate entry type in the Automated Commercial Environment (ACE) by a party qualified to make such entry.

(b) Shipments sent through the international postal network that would otherwise qualify for the de minimis exemption under 19 U.S.C. 1321(a)(2)(C) shall pass free of any duties except those specified in section 3 of this order, and without the preparation of an entry by U.S. Customs and Border Protection (CBP), until such time as CBP establishes a new entry process and publishes that process in the Federal Register.

Sec. 3. Duty Rates for International Postal Shipments. (a) Transportation carriers delivering shipments to the United States through the international postal network, or other parties if qualified in lieu of such transportation carriers, must collect and remit duties to CBP using the methodology described in either subsection (b) or (c) of this section. Each transportation carrier shall apply the same methodology across all covered shipments during any given period but may change its methodology no more than once per calendar month, or on another schedule determined to be appropriate by CBP, upon providing at least 24 hours’ notice to CBP.

(b) A duty equal to the effective IEEPA tariff rate applicable to the country of origin of the product shall be assessed on the value of each dutiable postal item (package) containing goods entered for consumption.

(c) A specific duty shall be assessed on each package containing goods entered for consumption, based on the effective IEEPA tariff rate applicable to the country of origin of the product as follows:

(i) Countries with an effective IEEPA tariff rate of less than 16 percent: $80 per item;

(ii) Countries with an effective IEEPA tariff rate between 16 and 25 percent (inclusive): $160 per item; and

(iii) Countries with an effective IEEPA rate above 25 percent: $200 per item.

(d) For all international postal shipments subject to the methodologies described in subsections (b) and (c) of this section, the country of origin of the article must be declared to CBP.

(e) The specific duty methodology provided for in subsection (c) of this section shall be available for transportation carriers to select for a period of 6 months from the effective date of this order. After such time all shipments to the United States through the international postal network must comply with the ad valorem duty methodology in subsection (b) of this section.

(f) Shipments sent through the international postal network that are subject to antidumping and countervailing duties or a quota must continue to be entered under an appropriate entry type in ACE to the extent required by all applicable regulations.

Sec. 4. Implementation. (a) The requirements and procedures established by sections 2 and 3 of this order shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 29, 2025.

(b) The provisions of this order supersede section 2 of Executive Order 14256, as amended, with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 29, 2025.

(c) Consistent with applicable law, the Secretary of Homeland Security is directed and authorized to take all necessary actions to implement and effectuate this order — including through temporary suspension or amendment of regulations or through notices in the Federal Register and by adopting rules, regulations, or guidance — and to employ all powers granted to the President by IEEPA as may be necessary to implement and effectuate this order. The Secretary of Homeland Security, in consultation with the United States International Trade Commission (ITC), shall determine whether modifications to the Harmonized Tariff Schedule of the United States are necessary to effectuate this order and may make such modifications through notice in the Federal Register. The Secretary of Homeland Security shall consult with the Secretary of State, the Secretary of the Treasury, the Attorney General, the Secretary of Commerce, the United States Trade Representative, the ITC, and the Postmaster General, where appropriate. The Secretary of Homeland Security may, consistent with applicable law, redelegate any of these functions within the Department of Homeland Security. All executive departments and agencies shall take all appropriate measures within their authority to implement this order.

(d) To ensure remittance of duties in accordance with this order, and to assure compliance with other legal requirements, CBP is authorized to require a basic importation and entry bond as described in 19 C.F.R. 113.62 for informal entries valued at or less than $2,500. Any carrier that transports international postal shipments to the United States, by any mode of transportation, must have an international carrier bond as described in 19 C.F.R. 113.64 to ensure payment of the duties described in section 3 of this order. CBP is authorized to ensure that the international carrier bonds required by this subsection are sufficient to account for the duties described in section 3 of this order.

Sec. 5. Definition. As used in this order, the term “effective IEEPA tariff rate” means the total duty rate imposed on articles to address a national emergency declared under IEEPA, including Executive Order 14257, as amended; Executive Order 14193; as amended, Executive Order 14194, as amended; and Executive Order 14195, as amended, in accordance with the stacking rules set out in Executive Order 14289 of April 29, 2025 (Addressing Certain Tariffs on Imported Articles), and any subsequent order or proclamation addressing stacking or the applicability of tariffs imposed under IEEPA.

Sec. 6. Severability. (a) If any provision of this order or the application of any provision of this order to any individual or circumstance is held to be invalid, the remainder of this order and the application of its provisions to any other individuals or circumstances shall not be affected.

(b)(i) If the additional duties imposed under Executive Order 14193, as amended, Executive Order 14194, as amended, Executive Order 14195, as amended, or Executive Order 14257, as amended, are held to be invalid, the suspension of, or continued suspension of, duty-free de minimis treatment, as detailed in this order, shall not be affected. Duty-free de minimis treatment would still be suspended, whether pursuant to my authority under 50 U.S.C. 1702(a)(1)(B) to “regulate . . . importation” or my authority under that provision to “nullify” or “void” “exercising any right . . . or privilege with respect to . . . any property,” in the way and to the extent explained in this order, to deal with the emergencies declared in Executive Order 14193, as amended, Executive Order 14194, as amended, Executive Order 14195, as amended, or Executive Order 14257, as amended. Such suspensions are still necessary and appropriate to address the unusual and extraordinary threats to the national security, foreign policy, and economy of the United States. Each determination to suspend or continue to suspend duty-free de minimis treatment is still independent from the other determination and made only with the purpose to deal with the respective emergency and not for the purpose of dealing with another emergency. CBP is directed and authorized to take all necessary actions consistent with applicable law to implement and effectuate this order in line with this section ‑- including through temporary suspension or amendment of regulations or through notices in the Federal Register and by adopting rules, regulations, or guidance — and to employ all powers granted to the President by IEEPA as may be necessary to implement and effectuate this order in line with this section.

(ii) Duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) shall remain available for postal shipments until notification by the Secretary to the President that adequate systems are in place to fully and expeditiously process and collect duties applicable for postal shipments otherwise eligible for duty-free de minimis treatment. After such notification, duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) shall not be available for postal shipments.

Sec. 7. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:

(i) the authority granted by law to an executive

department or agency, or the head thereof; or

(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.

(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.

(d) The costs for publication of this order shall be borne by the Department of Homeland Security.

https://www.whitehouse.gov/presidential-actions/2025/07/suspending-duty-free-de-minimis-treatment-for-all-countries/

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

International Traffic in Arms Regulations: Updates to § 126.1 Country Policies and Minor Revisions

July 7, 2025: 90 Fed. Reg. 29720: DDTC has published a final rule in the Federal Register updating the International Traffic in Arms Regulations’ (ITAR) § 126.1 country policies for the Central African Republic, the Democratic Republic of the Congo, Haiti, Libya, Somalia, South Sudan, and Sudan. These updates codify in the ITAR recent United Nations Security Council resolutions. The Department is also making several clarifications and corrections in the ITAR, including updates to the list of North Atlantic Treaty Organization (NATO) members and major non-NATO allies, as well as revising ITAR § 126.1(a) to improve its readability.

The changes are summarized as follows:

(1) Removing a requirement to pre-notify the DRC Sanctions Committee of shipments of arms and related materiel to the government of the Democratic Republic of the Congo;

(2) Permitting case-by-case consideration of exports to Haiti of (a) defense articles and services that have been pre-approved by the UN Security Council Haiti Sanctions Committee and (b) non-lethal military equipment only for humanitarian or protective use and related technical assistance or training;

(3) Implementing revisions of the UN arms embargo on Libya, including permitting specified exports and temporary exports;

(4) Implementing a Dec. 1, 2023, UNSC resolution formally lifting the prior nationwide arms embargo on Somalia;

(5) Implementing a July 30, 2024, UNSC resolution easing the arms embargo on the Central African Republic;

(6) Removing a provision that had allowed for a case-by-case review of export licenses or other approvals involving help and supplies in support of implementation of a peace agreement in Sudan;

(7) Implementing UNSC resolutions regarding the arms embargo on South Sudan;

(8) Updating the list of North Atlantic Treaty Organization members to add Finland and Sweden; and

(9) Updating the list of major non-NATO allies by adding Colombia, Kenya, and Qatar and removing Afghanistan.

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

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=ebdaa39697ea6a5067b1791ad053af05

https://www.federalregister.gov/documents/2025/07/07/2025-12560/international-traffic-in-arms-regulations-updates-to-certain-proscribed-countries-and-other-changes

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ITAR Updates to Certain Proscribed Countries and Other Changes – Affected Sections Redline and Updated ITAR Reorg Redline

July 8, 2025: 90. Fed. Reg. 29720: On July 7, 2025, the Department published a final rule (90 FR 29720) amending ITAR sections 120.23, 120.54, and 126.1. To assist users of the ITAR, the Department provides here a redline of sections affected by that rule and a link to the updated ITAR Reorg redline.

DDTC provides these redlines as a service to the public but notes that it is not intended to be a substitute for any official publication of the U.S. Government. We direct your attention to the annual edition of the Code of Federal Regulations and to the e-CFR system for the actual regulatory text.

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=8f89a87e9722629067b1791ad053afc1

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=c6090afa97b266100083b3b0f053af2c

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Updating Cuba Restricted List

July 14, 2025: 90. Fed. Reg. 31558: The Department of State added seven Cuban military-controlled hotels to the List of Restricted Entities and Sub entities Associated With Cuba (Cuba Restricted List or CRL) identifying entities and sub entities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. The Cuban Assets Control Regulations generally prohibit a person subject to U.S. jurisdiction from having direct financial transactions with the entities and sub entities on the CRL. The Department of Commerce's Bureau of Industry and Security generally will deny applications to export or reexport items for use by entities or sub entities on the CRL.

https://www.federalregister.gov/documents/2025/07/14/2025-13149/updating-cuba-restricted-list

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DDTC Name And Address Changes Posted To Website

July 2 through July 14, 2025: 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:

Change in Address of Saab AB (publ), Business Area Surveillance from Nettovagen 6, SE-175 88 Jarfalla, Sweden to Solna strandvag 10, SE 171 54 Solna, Sweden;
Change in Name of Piaggio Aero Industries S.p.A to Baykar Aerospace S.p.A due to acquisition;
Change in Name of Bollore Logistics SE to CEVA Air & Ocean International SE due to acquisition;
Change in Name of Econocom Workplace Infra Innovation to Econocom Services & Solutions due to corporate restructuring;
Change in Name of ATLAS ELEKTRONIK UK Limited to TKMS ATLAS UK Limited due to merger.

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DDTC Frequently Asked Questions (FAQs)

Q: Are individuals who are recipients of grants issued in accordance with the Deferred Action for Childhood Arrivals (DACA) policy of the United States Government considered U.S. persons under the ITAR?

A: No, individuals granted DACA status do not fall withing the ITAR definition of a U.S. person (ITAR § 120.62) by virtue of the issuance of their DACA status. Issuance of an employment authorization document by U.S. Citizenship and Immigration Services to such recipients does not mean that an individual is a lawful permanent resident or a protected individual as defined in 8 U.S.C. § 1101(a)(2) or 8 U.S.C. § 1324b(a)(3).

Q: Is a U.S. person who is also a citizen of another country a U.S. person, a foreign person, or both?

A: Under the ITAR, a person is either a U.S. person or a foreign person. If a person meets the definition of a U.S. person at ITAR § 120.62, by definition they are not a foreign person as defined in ITAR § 120.63. This means that a U.S. person who is a citizen of a foreign country (e.g., a lawful U.S. permanent resident who is not a U.S. citizen) is a U.S. person and not a foreign person. Similarly, a U.S. person who is a U.S. citizen and also holds the citizenship of another country is a U.S. person and not a foreign person.

Q: When is a foreign person considered an employee?

A: A foreign person is considered an employee when the foreign person is a full time regular employee, directly paid, insured, hired/fired and/or promoted exclusively by the U.S. person. The employee, however, need not LIVE in the U.S. to be employed by the U.S. person. The U.S. person is liable to ensure all foreign person employees are compliant with U.S. export laws regardless of residence.

Q: Should freight forwarders be identified on agreements (TAAs, MLAs, WDAs)?

A: Freight forwarders should not be identified in agreement submissions. Freight forwarders should only be identified in licenses in furtherance of (IFO) an agreement. See the DDTC Agreement Guidelines when utilizing the § 123.16(b) exemption regarding how to identify freight forwarders.

Q: On what type of export authorization from DDTC should the Applicant identify foreign freight forwarders that will move hardware from a foreign signatory of a Warehousing and Distribution Agreement (WDA) to an authorized end user in the Distribution Territory of that WDA?

A: The foreign freight forwarders should be identified on the DSP-5 in furtherance of the WDA for the original export of the hardware from a U.S. signatory to a foreign signatory of the WDA. Alternatively, such foreign freight forwarders can be included as sublicensees to the WDA. Lastly, a foreign signatory to the WDA may obtain retransfer/reexport authorization from DDTC to identify the foreign freight forwarders that transport the hardware to the authorized end user in the Distribution Territory of the WDA.

Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Lebanon

July 11, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Lebanon has requested to buy support equipment, and other related elements of logistics program and support that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $43.7 million ($0 in MDE), included Cartridge Actuated Devices and Propellent Actuated Devices (CAD/PADs); engine components, parts, and accessories; aircraft engine and ground handling equipment; major and minor modifications; aircraft components, spares, and accessories; spare parts, consumables, and accessories, and repair and return support; unclassified software delivery and support; unclassified publications and technical documentation; clothing, textiles, and individual equipment; transportation support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $100 million.
The principal contractor will be Sierra Nevada Corporation (SNC), located in Sparks, NV. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4241763/lebanon-a-29-super-tucano-aircraft-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Norway

July 11, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Norway has requested to buy up to nine (9) HH-60W helicopters; twenty-two (22) T-700-GE-401 turboshaft engines; twenty-one (21) Embedded Global Positioning System/Inertial Navigation Systems (GPS/INS) (EGI) (18 installed, 3 spares); ten (10) AN/APR-52 Radar Warning Receivers (RWR) (9 installed, 1 spare); and ten (10) AN/AAR-57 Common Missile Warning Systems (CMWS) (9 installed, 1 spare). The following non-MDE items will also be included: GAU-21 aircraft machine guns and other machine guns; IZLID 200P infrared lasers; AN/ALE-47 Airborne Countermeasures Dispenser Systems; Joint Mission Planning System with unique planning components and software; Computer Program Identification Numbers (CPINs); weapons and weapons support equipment; major and minor modifications and maintenance support; instruments and lab equipment; training aids, devices, and spare parts; consumables, accessories, and repair and return support; electronic warfare database support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; aircraft ferry and transportation support; facilities and construction support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $2.6 billion. The principal contractor will be Sikorsky Aircraft Corporation, located in Stratford, CT. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to Norway.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4241742/norway-hh-60w-helicopters

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DSCA Notifies Congress of Potential FMS Sale To Bulgaria

July 21, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Bulgaria has requested to buy a Naval Strike Missile Coastal Defense System (NSM CDS), including three (3) Link-16 Multifunctional Information Distribution System – Joint Tactical Radio Systems (MIDS-JTRS) and the following non-MDE items: tactical Naval Strike Missiles (NSM); inert NSM handling; telemetered NSM; operational, inert NSM; mobile fire control centers with associated communications equipment; mobile missile launch vehicles with associated communications equipment; NSM transport loading vehicles; NavStrike-M Global Positioning System receiver; operator trainer consoles; Simple Key Loaders (SKL); and associated support including but not limited to technical publications, training documentation, technical data packages, support equipment, software support spare parts, training, training simulators, integration services, and U.S. government and original equipment manufacturer technical assistance; and other related elements of logistics and program support. The estimated total cost is $620 million. The principal contractor will be Kongsberg Defence and Aerospace AS, located in Kongsberg, Norway. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4250841/bulgaria-naval-strike-missile-coastal-defense-system

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

July 23, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy sustainment related articles and services for the HAWK missile system, including: five-ton cargo trucks; HAWK system spare parts; refurbishment and system overhaul of HAWK air defense fire units; tool kits; test equipment; support equipment; technical documentation; training; U.S. Government and contractor technical and field office support; U.S. Government and contractor technical assistance; storage containers and equipment related to spare parts storage; MIM-23 HAWK missile spare parts and missile repair; and other related elements of logistics and program support. The estimated total program cost is $172 million. The principal contractors will be Sielman Corporation, located in Volos, Greece; RTX Corporation, located in Andover, MA; and PROJECTXYZ, located in Huntsville, AL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4253428/ukraine-hawk-phase-iii-missile-system-and-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

July 23, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services for the refurbishment of Bradley Infantry Fighting Vehicles, technical assistance, training, publications, and other related elements of logistics and program support. The estimated total cost is $150 million. The principal contractors will be BAE Systems, Cummins Inc., Leonardo DRS Inc., and Renk Group AG, with all work occurring in Europe. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4253473/ukraine-bradley-infantry-fighting-vehicles-and-maintenance-repair-and-overhaul

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

July 24, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services to support the training, sustainment, and refurbishment measures of existing U.S.-origin air defense systems. The following non-MDE items will be included: major modifications and maintenance support; spare parts, consumables and accessories, and repair and return support; 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 $180 million. The principal contractors will be Sierra Nevada Corporation, located in Sparks, NV; V2X, Inc., located in McLean, VA; Radionix, located in Kyiv, Ukraine; and Systems Electronic Export, located in Kyiv, Ukraine. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4254530/ukraine-air-defense-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

July 24, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services for the refurbishment of M109 self-propelled howitzers, technical assistance, training, publications, and other related elements of logistics and program support. The estimated total cost is $150 million. The principal contractors will be BAE Systems, Daimler Truck North America, and Allison Transmission Inc., with all work occurring in Europe. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4254520/ukraine-m109-self-propelled-howitzer-maintenance-repair-and-overhaul-capability

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DSCA Notifies Congress of Potential FMS Sale To Egypt

July 24, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Egypt has requested to buy the National Advanced Surface-to-Air Missile System (NASAMS), that includes: four (4) AN/MPQ-64F1 Sentinel radar systems with associated support equipment; one hundred (100) Advanced Medium Range Air-to-Air Missiles (AMRAAM)-Extended Range (ER); one hundred (100) Air Intercept Missile (AIM)-120C-8 AMRAAMs; two (2) AIM-120C-8 AMRAAM guidance sections (spares); one (1) AMRAAM control section (spare); six hundred (600) AIM-9X Sidewinder Block II tactical missiles; one hundred fifty (150) AIM-9X Sidewinder Captive Air Training Missiles (CATMs); sixty-two (62) AIM-9X Sidewinder Block II tactical guidance units (GUs); and twenty (20) AIM-9X Sidewinder CATM GUs. The following non-MDE items will also be included: fire distribution centers (FDC); canister launcher systems; electrooptical/infrared systems; Tactical Control Center systems; NASAMS classroom trainer; communication node systems; IPS 250X High Assurance Internet Protocol Encryptions (HAIPE); Identification Friend or Foe (IFF) Model 5800 or TPX-61; KIV-77 IFF crypto appliqué; AN/PSN-13 Defense Advanced Global Positioning System Receivers (DAGRs) with Selective Availability Anti-Spoofing Module (SAASM); AN/PYQ-10 Simple Key Loaders (SKLs), code loaders, and cable sets; AMRAAM-ER Extended Load Trainers (ELTs); missile containers; weapon system support and test equipment; spare and repair parts, consumables, accessories, and repair and return support; 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 $4.67 billion. The prime contractor will be RTX Corporation, located in Andover, MA. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4254503/egypt-national-advanced-surface-to-air-missile-system

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U.S. Census Bureau

Schedule B and Harmonized Tariff Schedule (HTS) Updated in the Automated Export System (AES)

July 2, 2025:

Effective immediately, the Schedule B, Harmonized Tariff Schedule (HTS), and HTS Codes That Are Not Valid for AES tables have been updated to accept the changes to the July 1, 2025 codes.

AES will accept shipments with outdated codes during a grace period for 30 days beyond the expiration date of June 30, 2025. Reporting an outdated code after the 30-day grace period will result in a fatal error.

The ACE AESDirect program has been updated with the 2025 codes and will accept shipments with outdated codes during the grace period as well.

The 2025 Schedule B and HTS tables are available for downloading at:

https://www.census.gov/foreign-trade/aes/concordance.html

The current list of HTS codes that are not valid for AES are available at:

https://www.census.gov/foreign-trade/aes/documentlibrary/concordance/hts-not-for-aes.txt

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Update to Automated Export System (AES) Response Message 15A

July 2, 2025:

CSMS # 65520566 - Update to Automated Export System (AES) Response Message 15A

This message is a follow-up to the broadcast released on May 11, 2022, titled Expansion of Foreign Trade Zone Identifier to 9-characters (Effective May 17, 2022).

The severity of Response Message 15A is being upgraded from “Compliance” to a severity of “Fatal” July 14, 2025. This is to ensure further compliance with the changes outlined in Federal Register Notice 85 FR 60479 that requires the expansion of the Foreign Trade Zone Identifier from 7 to 9-characters. This change is effective immediately in CERT for testing.

Response Code: 15A

Narrative Text: FTZ MUST BE 9 CHARACTERS ALPHANUMERIC

Severity: FATAL

Reason: The Foreign Trade Zone Indicator reported on the SC2 record does not have the required format of 3 numeric characters which is a valid zone followed by 6 alphanumeric characters.

Resolution: The Foreign Trade Zone Indicator must be specified in the required format. The first 3 positions must be numeric and represent the general purpose zone. The next 3 positions are alphanumeric and represent the subzone. The last 3 positions are alphanumeric and represent the site. The Foreign Trade Zone Indicator must be left justified with no trailing spaces. Insert zeros when there is no sub zone or site. Report leading zero(s) when the general purpose zone is less than 3 numerics, and when the subzone or site is 1 alphanumeric. Verify the Foreign Trade Zone Indicator, correct the SC2 record and retransmit.

Contact your assigned CBP Client Representative for programming and testing questions.

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How to Resolve Common AES Response Messages

July 15, 2025:

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

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

Response Code: 628

Narrative: 1^st Unit of Measure Code / Schedule B/HTS Mismatch

Severity: Fatal

Reason: The Unit of Measure (1) reported does not match the Unit of Measure (1) required for the Schedule B/ HTS Number reported.

Resolution: The Unit of Measure (1) must match exactly the Unit of Measure (1) prescribed by the Schedule B/HTS Number reported. See Appendix K – Units of Measure Codes

Verify the Unit of Measure (1) required for the reported Schedule B/HTS Number, 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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LATEST SANCTIONS FINES & PENALTIES

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

Fines and Penalties

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

July 2, 2025: The Bureau of Industry and Security, U.S. Department of Commerce has notified Unicat Catalyst Technologies, LLC, of Alvin, Texas, as successor to Unicat Catalyst Technologies, Inc., (“Unicat”), of its intention to initiate an administrative proceeding against Unicat pursuant to Section 766.3 of the Export Administration Regulations (the “Regulations”), through the issuance of a Proposed Charging Letter to Unicat that alleges that Unicat committed three violations of the Regulations.

https://media.bis.gov/news-updates

https://media.bis.gov/media/1635

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July 21, 2025: Brian Assi, also known as Brahim Assi, 63, of Beirut, Lebanon, was sentenced to 44 months in prison for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR), attempted unlawful export of goods from the United States to Iran without a license, attempted smuggling goods from the United States, submitting false or misleading export information, and conspiracy to commit money laundering.

https://www.justice.gov/opa/pr/foreign-national-sentenced-conspiring-export-us-made-drill-rigs-iran-violation-us-sanctions

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July 21, 2025: José Adolfo Macías Villamar, also known as “Fito,” a citizen of Ecuador, was arraigned at the federal courthouse in Brooklyn for crimes committed as the leader of Los Choneros, a transnational criminal organization based in Ecuador that is responsible for significant drug trafficking into the United States, firearms trafficking from the United States, and acts of extreme violence. Macías Villamar was arraigned on a seven-count superseding indictment charging him with international cocaine distribution conspiracy; international cocaine distribution; using firearms in furtherance of drug trafficking; smuggling firearms from the United States; and straw purchasing of firearms conspiracy. Macías Villamar will be arraigned before United States Chief Magistrate Judge Vera M. Scanlon after being extradited from Ecuador to the Eastern District of New York.

https://www.justice.gov/usao-edny/pr/jose-adolfo-fito-macias-villamar-leader-los-choneros-transnational-criminal-0

https://media.bis.gov/news-updates

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July 28, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) imposed an administrative penalty of $95 million against Cadence Design Systems Inc. (Cadence) for illegal exports of Electronic Design Automation (EDA) hardware and software and semiconductor design technology to parties on the Entity List, an export controls blacklist. This is in addition to a concurrent agreement that Cadence signed with the U.S. Department of Justice which includes $45 million in forfeitures.

In a settlement agreement with BIS, Cadence admitted that employees of its Chinese subsidiary knowingly transferred sensitive U.S. technology to entities that develop supercomputers in support of China’s military modernization and nuclear weapons programs namely the National University of Defense Technology (NUDT), Tianjin Phytium Information Technology (Phytium), and other Entity List parties.

Under the terms of the BIS settlement agreement, Cadence admitted to 56 violations of the EAR between September 2015 and September 2020, for selling EDA products to NUDT through an alias, Central South CAD Center (CSCC). Cadence exported EDA hardware and software, and semiconductor design technology, valued at $45,305,317.41 to CSCC with knowledge or reason to know that NUDT would be the end-user. Cadence maintained a sales relationship with NUDT for years after NUDT’s placement on the Entity List using an account assigned to CSCC and had reason to know CSCC was closely linked to NUDT, including that equipment sold or loaned to CSCC was installed on the NUDT campus and that CSCC and NUDT shared personnel.

https://media.bis.gov/press-release/cadence-design-systems-pay-95-million-penalty-bis-unauthorized-exports-chinese-entities-tied-development

https://bis.gov/media/documents/cadence-design-systems-final-order-7.28.2025.pdf

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

July 2, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $608,825 settlement with Key Holding, LLC. Key Holding agreed to settle its potential civil liability for 36 apparent violations of OFAC sanctions on Cuba that arose from the conduct of a Key Holding subsidiary in Colombia that managed the logistics for freight shipments to Cuba. The settlement amount reflects OFAC's determination that the apparent violations were non-egregious and voluntarily self-disclosed. For more information, please see the following Enforcement Release.

https://ofac.treasury.gov/recent-actions/20250702

https://ofac.treasury.gov/media/934456/download?inline

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July 8, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $1,454,145 settlement with Harman International Industries, Inc. Harman agreed to settle its potential civil liability for 11 apparent violations of OFAC sanctions on Iran. Over a period of more than two years, overseas employees of a U.S. subsidiary of Harman enabled the diversion of its products from its United Arab Emirates distributor to Iran. The settlement amount reflects OFAC's determination that the apparent violations were egregious and voluntarily self-disclosed. For more information, please see the following Enforcement Release and settlement agreement.

https://ofac.treasury.gov/media/934471/download?inline and

https://ofac.treasury.gov/media/934476/download?inline

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July 15, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an $11,832,136 settlement with Interactive Brokers LLC (IB). IB agreed to settle its potential civil liability for apparent violations of several OFAC sanctions programs that arose from IB’s provision of brokerage and investment services to persons in Iran, Cuba, Syria, and the Crimea region of Ukraine, processing of trades in securities subject to the Chinese Military-Industrial Complex program, processing of transactions involving blocked persons under OFAC’s Russia, Global Magnitsky, Venezuela, and Syria sanctions programs, and engagement in new investment in the Russian Federation. OFAC determined IB’s conduct was non-egregious and voluntarily self-disclosed. For more information, please visit the following Enforcement Release.

https://ofac.treasury.gov/recent-actions/20250715

https://ofac.treasury.gov/media/934501/download?inline

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July 29, 2025: The Bureau of Industry and Security, U.S. Department of Commerce (“BIS”), has notified Inc., of its intention to initiate an administrative proceeding against Andritz Inc. pursuant to Section 766.3 of the Export Administration Regulations (the “Regulations”), through the issuance of a Proposed Charging Letter to Andritz Inc. that alleges that Andritz Inc. committed 36 violations of the Regulations. Specifically:

STATEMENT OF CHARGES

Charges 1 - 36 15 C.F.R. § 764.2(a) – Engaging in Prohibited Conduct

As described in the Schedule of Violations, between on or about May 25, 2023, through on or about February 12, 2024, Andritz Inc. engaged in conduct prohibited by the Regulations on 36 occasions when it exported refiner plates, valued at $3,154,794.36, to Andritz Fiedler. Andritz Fiedler then reexported the refiner plates to Russia. The sales to Russia were conducted without the requisite license or other authorization from BIS.

The items reexported by Andritz Fiedler are classified EAR99. However, because these items were classified by Harmonized Tariff Schedule (“HTS”) codes which appeared on Supplement No. 4 to Part 746 of the EAR at the time of export, these items required a license for export to Russia pursuant to § 746.8 of the EAR. On May 23, 2023, BIS added license requirements for the items to limit Russia’s access to items that enable its military capabilities and to sources of revenue that could support those capabilities. 88 Fed. Reg. 33422. Refiner plates are used in the refining process of paper pulp making machines. Paper pulp is a basic component of manufacturing paper. While there is no evidence that Andritz Inc.’s refiner plates were designed for, used, or could be used, for military-related purposes, wood and flax pulp could potentially have military application.

Supplement No. 4 to Part 746 of the Regulations identifies ‘industrial goods’ which require a BIS license for export, reexport, or transfer (in-country) to Russia or Belarus. For the purposes of this license requirement, an ‘industrial good’ is any item identified in Supplement No. 4 to Part 746 of the Regulations. The HTS classifications of the items contained in each of Andritz Inc.’s 36 exports are detailed in the Schedule of Violations below.

Upon learning of the transactions, Andritz Inc. took immediate steps to investigate the matter, voluntarily disclosed the transactions in a timely fashion to BIS, and retained outside counsel to investigate. According to information it voluntarily disclosed to BIS, Andritz Inc. exported refiner plates to Andritz Fiedler without the requisite license. Andritz Fielder then sold and shipped the refiner plates to entities within Russia.

In total, from on or about May 25, 2023, through on or about February 12, 2024, Andritz Inc. engaged in 36 transactions involving the reexport of refiner plates. Each of these transactions involved items classified by an HTS code listed in Supplement No. 4 to Part 746 of the EAR and required a license for export to Russia pursuant to § 746.8(a)(5) of the EAR.

By engaging in 36 reexports to Russia without the requisite license or other authorization from BIS, Andritz Inc. committed 36 violations of § 764.2(a) of the Regulations.

https://media.bis.gov/press-release/bis-reaches-administrative-enforcement-settlement-andritz-inc.-order

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Sanctions

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

July 1, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Aeza Group, a bulletproof hosting (BPH) services provider, for its role in supporting cybercriminal activity targeting victims in the United States and around the world. BPH service providers sell access to specialized servers and other computer infrastructure designed to help cybercriminals like ransomware actors, personal information stealers, and drug vendors evade detection and resist law enforcement attempts to disrupt their malicious activities. OFAC is also designating two affiliated companies and four individuals who are Aeza Group leaders. Finally, in coordination with the United Kingdom’s (UK) National Crime Agency (NCA), OFAC is designating an Aeza Group front company in the UK.

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

Bozoyan, Yurii Meruzhanovich of Russia;
Gast, Valdimir Vyacheslavovich of Russia;
Knyazev, Igor Anatolyevich of Russia; and
Penzev, Arsenii Aleksandrovich of Russia.

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

Aeza Group LLC of Russia;
Aeza International, Ltd. of the United Kingdom;
Aeza Logistics LLC of Russia; and
Cloud Solutions LLC of Russia.

https://ofac.treasury.gov/recent-actions/20250701

https://home.treasury.gov/news/press-releases/sb0185

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July 3, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against networks that have collectively transported and purchased billions of dollars’ worth of Iranian oil, some of which has benefited Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. Among the entities sanctioned is a network of companies run by Iraqi businessman Salim Ahmed Said (Said) that has profited from smuggling Iranian oil disguised as, or blended with, Iraqi oil. Treasury also sanctioned several vessels engaged in the covert delivery of Iranian oil, intensifying pressure on Iran’s “shadow fleet.”

The following individual has been added to OFAC’s SDN List:

Said, Salim Ahmed of the United Arab Emirates.

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

Aria Sina Control International Technical Inspection Co. of Iran;
Asian Sean Angel Shipping Co of Iran;
Betensh Global Investment Limited and Dong Dong Shipping Limited of the Virgin Islands;
Breeze Marine Asset Management Inc of the Marshall Islands;
Dima Shipping and Trading Company of Turkey;
Egir Shipping Ltd of Mahe Island;
Fotis Lines Incorporated of the Marshall Islands;
Grat Shipping Co Ltd of Mahe Island;
Isle Innovation Inc of Panama;
Keval Methanol Company of Iran;
Rhine Shipping DMCC of the United Arab Emirates;
Robinbest Limited of the United Kingdom;
Sai Saburi Consulting Services Private Limited of India;
Tashilat Sarl of India;
The Willet Hotel Limited of the United Kingdom;
Themis Limited of the Marshall Islands;
Trans Arctic Global Marine Services Pte. Ltd. of Singapore;
VS Oil Terminal FZE of the United Arab Emirates;
VS Petroleum DMCC of the United Arab Emirates;
VS Tankers Free Zone Entity of the United Arab Emirates; and
White Sands Shipment Corp of Seychelles.

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

Artemis III (HQZY4) Crude Oil Tanker Honduras flag; MMSI 334983000 (vessel);
Atila (TJM0033) Crude Oil Tanker Cameroon flag; MMSI 613769400 (vessel);
Bateleur (HOA5120) LPG Tanker Panama flag; MMSI 352980786 (vessel);
Bianca Joysel (3E2106) Crude Oil Tanker Panama flag; MMSI 352001069 (vessel);
Dijilah (V7A2015) Crude Oil Tanker Marshall Islands flag; MMSI 538008147 (vessel):
Elizabet (TJMC263) Crude Oil Tanker Cameroon flag; MMSI 613001301 (vessel);
Fotis (D6A3948) LPG Tanker Comoros flag; MMSI 620999948 (vessel);
Gas Maryam (T8A4824) LPG Tanker Palau flag; MMSI 511101457 (vessel);
Neel (3E2234) LPG Tanker Panama flag; MMSI 352002246 (vessel);
Rieveria I (T7BC7) Crude Oil Tanker San Marino flag; MMSI 268245201 (vessel);
Themis (3EFU8) Crude Oil Tanker Panama flag; MMSI 353744000 (vessel); and
VIZURI (TJMC707) Crude Oil Tanker Cameroon flag; MMSI 613742000 (vessel).

https://ofac.treasury.gov/recent-actions/20250703

https://home.treasury.gov/news/press-releases/sb0188

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July 3, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned seven senior officials and one entity associated with the Hizballah-controlled financial institution Al-Qard Al-Hassan (AQAH), which was designated by OFAC in 2007. These officials have served in senior management roles for AQAH and have facilitated the evasion of U.S. sanctions, enabling Hizballah’s access to the formal financial system. This action underscores Treasury’s commitment to disrupting Hizballah’s sanctions evasion schemes and supporting efforts by the new Lebanese government to limit the terrorist group’s influence, particularly as entities like AQAH continue to undermine the already fragile Lebanese economy.

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

Badir, Mohammed Suleiman of Lebanon;
Bezz, Imad Mohammad of Lebanon;
Fawaz, Samer Hasan of Lebanon;
Jamil, Nehme Ahmad of Lebanon;
Karnib, Ali Mohamad of Lebanon;
Kassir, Issa Hussein of Lebanon;
Krishi, Ali Ahmad of Lebanon; and
Said, Salim Ahmed of Lebanon.

https://home.treasury.gov/news/press-releases/sb0189

https://ofac.treasury.gov/recent-actions/20250703

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July 7, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40D, "Authorizing the Offloading of Liquefied Petroleum Gas in Venezuela."

GENERAL LICENSE NO. 40D: “Authorizing the Offloading of Liquefied Petroleum Gas in Venezuela”

All transactions that are ordinarily incident and necessary to the delivery and offloading of liquefied petroleum gas in Venezuela, 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 prohibited by Executive Order (E.O.) 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019, or E.O. 13884 of August 5, 2019, each as incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized through 12:01 a.m. eastern daylight time, September 5, 2025, provided the liquified petroleum gas was loaded on a vessel on or before July 7, 2025.

https://ofac.treasury.gov/media/934461/download?inline

https://ofac.treasury.gov/recent-actions/20250707

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July 8, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related General License 13N, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024."

GENERAL LICENSE NO. 13N: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”

S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, October 9, 2025.

https://ofac.treasury.gov/media/934466/download?inline

https://ofac.treasury.gov/recent-actions/20250708

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July 8, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Song Kum Hyok, (Song), a malicious cyber actor associated with the sanctioned Democratic People’s Republic of Korea (DPRK) Reconnaissance General Bureau (RGB) hacking group Andariel.

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

Asatryan, Gayk of Russia; and
Song, Kum Hyok of North Korea.

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

Asatryan Limited Liability Company of Russia;
Fortuna Limited Liability Company of Russia;
Korea Saenal Trading Corporation of North Korea; and
Korea Songkwang Trading General Corporation of North Korea.

https://ofac.treasury.gov/recent-actions/20250708_33

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July 8, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 13N, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.”

GENERAL LICENSE NO. 13N: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”

S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, October 9, 2025.

https://ofac.treasury.gov/media/934466/download?inline

https://ofac.treasury.gov/recent-actions/20250708

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July 9, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 22 entities based in Hong Kong, the United Arab Emirates (UAE), and Türkiye for their roles in facilitating the sale of Iranian oil that benefits the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). The IRGC-QF is Iran’s most powerful paramilitary force and a designated Foreign Terrorist Organization (FTO).

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

Amito Trading Limited of China;
Bright Spot Goods Wholesalers of the United Arab Emirates;
Cetto International Limited of Hong Kong;
Finesse Global Trading Limited of China;
Future Resource Trading Limited of China;
Gah Petrochemical Trading Limited of China;
Golden Globe Demir Celik Petrol Sanayi Ve Ticarat Anonim Sirketi of Turkey;
JTU Energy Limited of China;
Lavida Corporation Limited of China;
Marcera Internation Limited of China;
Marmerth Limited of China;
Matallex Limited of China;
Mist Trading Co., Limited of China;
Moon Imp and Exp Co., limited of China;
Peakway Global Limited of China;
Pulcular Enerji Sanayi Vi Ticaret Anonim Sirketi of Turkey;
Queens Ring Limited of China;
Radix Trade Limited of China;
Shelf Trading Limited of China;
Star Oilgolbal Limited of China; and
Ventus Trade Limited of China.

https://ofac.treasury.gov/recent-actions/20250709

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July 9, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued ICC-related General License 8, “Authorizing the Wind Down of Transactions Involving Francesca Paola Albanese.”

GENERAL LICENSE NO. 8: “Authorizing the Wind Down of Transactions Involving Francesca Paola Albanese”

All transactions prohibited by the International Criminal Court-Related Sanctions Regulations (ICCSR), 31 CFR part 528, that are ordinarily incident and necessary to the wind down of any transaction involving Francesca Paola Albanese (Albanese), or any entity in which Albanese owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, August 8, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the ICCSR.

The following individual has been added to OFAC’s SDN List:

Albanese, Francesca Paola of Italy.

https://ofac.treasury.gov/recent-actions/20250709_33

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July 17, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Hector Rusthenford Guerrero Flores (a.k.a. “Niño Guerrero”)—the head of Tren de Aragua—and five other key Tren de Aragua leaders and affiliates. Tren de Aragua is a Foreign Terrorist Organization (FTO) that originated in Venezuela and continues to expand. Niño Guerrero has grown Tren de Aragua from a prison gang involved in extortion and bribery to an influential organization that threatens public safety throughout the Western Hemisphere. Tren de Aragua is involved in the illicit drug trade, human smuggling and trafficking, extortion, sexual exploitation of women and children, and money laundering, among other criminal activities.

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

Castillo Rondon, Felix Anner of Peru;
Guerrero Flores, Hector Rusthenford of Venezuela;
Perez Castillo, Wilmer Jose of Venezuela;
Rios Gomez, Wendy Marbelys of Colombia;
Romero, Yohan Jose of Venezuela; and
Santana Pena, Josue Angel of Venezuela.

https://ofac.treasury.gov/recent-actions/20250717

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July 22, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two individuals and five entities that profit through money laundering and importing petroleum products into territory controlled by Ansarallah, commonly known as the Houthis. The Iran-backed Houthis gain hundreds of millions of dollars annually by working with Yemeni businessmen to tax petroleum imports, generating critical revenue that funds the Houthis’ destabilizing activities in the region.

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

Al Wazir, Yahya Mohammed of Yemen; and
Al-Sunaydar, Muhammed of Yemen.

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

Al-Saida Stone For Trading And Agencies of Yemen;
Amran Cement Factory of Yemen;
Arkan Mars Petroleum Company For Oil Products Imports of Yemen;
Arkan Mars Petroleum DMCC of the United Arab Emirates; and
Arkan Mars Petroleum FZE of the United Arab Emirates.

https://ofac.treasury.gov/recent-actions/20250722

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July 24, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Korea Sobaeksu Trading Company and three associated individuals—Kim Se Un, Jo Kyong Hun, and Myong Chol Min—for their involvement in the evasion of U.S. and United Nations (UN) sanctions and efforts to generate revenue clandestinely for the Democratic People’s Republic of Korea (DPRK) government, including through fraudulent information technology (IT) worker schemes. This action to counter the DPRK’s wide-ranging revenue generation schemes is part of a collaborative effort with the Departments of Justice, Homeland Security, and State; the Federal Bureau of Investigation; and Homeland Security Investigations.

The following individual has been added to OFAC’s SDN List:

Jo, Kyong Hun of North Korea;
Kim, Se Un of North Korea; and
Myong, Chol Min of North Korea.

The following entity has been added to OFAC’s SDN List:

Korea Sobaeksu Trading Corporation of China.

https://ofac.treasury.gov/recent-actions/20250724

https://home.treasury.gov/news/press-releases/sb0205

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June 25, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Cartel de los Soles (a.k.a. Cartel of the Suns) as a Specially Designated Global Terrorist. Cartel de los Soles is a Venezuela-based criminal group headed by Nicolas Maduro Moros and other high-ranking Venezuelan individuals in the Maduro regime that provides material support to foreign terrorist organizations threatening the peace and security of the United States, namely Tren de Aragua and the Sinaloa Cartel.

The following entity has been added to OFAC’s SDN List:

Cartel De Los Soles of Venezuela.

https://ofac.treasury.gov/recent-actions/20250725

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July 30, 2025: In its largest Iran-related action since 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identifying more than 50 vessels that are part of the vast shipping empire controlled by Mohammad Hossein Shamkhani (Hossein). Hossein—the son of Ali Shamkhani, a top political advisor to the Supreme Leader of Iran—leverages corruption through his father’s political influence at the highest levels of the Iranian regime to build and operate a massive fleet of tankers and containerships. This network transports oil and petroleum products from Iran and Russia, as well as other cargo, to buyers around the world, generating tens of billions of dollars in profit.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Iran General License R, “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 30, 2025.”

GENERAL LICENSE R: “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 30, 2025”

All transactions prohibited by Executive Order (E.O.) 13902 that are ordinarily incident and necessary to one or more of the following activities involving the blocked vessels or blocked persons listed in the Annex to this general license, and any entity in which those blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, October 1, 2025, provided that any payment to a blocked person must be made into a blocked interest-bearing account located in the United States:

(1) The safe docking and anchoring in, and departure from, any port, excluding ports located in Iran or the Russian Federation, or under the control of the Government of Iran or the Government of the Russian Federation, of the blocked vessels listed in the Annex to this general license (the “Blocked Vessels”);

(2) The preservation of the health or safety of the crew of any of the Blocked Vessels;

(3) Emergency repairs of any of the Blocked Vessels or environmental mitigation or protection activities relating to any of the Blocked Vessels; or

(4) The delivery and offloading of cargo involving the Blocked Vessels, provided that the cargo was loaded on or before July 30, 2025 and that the delivery and offloading of cargo does not occur at any port located in Iran or the Russian Federation or under the control of the Government of Iran or the Government of the Russian Federation.

Please see full list of sanctioned individuals, entities, and vessels at the link below:

https://ofac.treasury.gov/recent-actions/20250730_33

https://ofac.treasury.gov/media/934536/download?inline

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JULY 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

Advanced Computing IC Controls – Impacts On Company Compliance Programs

Creighton Chin – Senior Associate – Compliance

FD Associates

On May 13, 2025, the U.S. Department of Commerce, Bureau of Industry & Security (“BIS”) published a policy statement, accompanied by two guidance documents, that introduced new license requirements under the Export Administration Regulations (“EAR”) for the exports, reexports, and transfers of Advanced Computing Integrated Circuits (IC), and other commodities for use with Artificial Intelligence (AI) models that support Weapons of Mass Destruction (WMD) and military-intelligence in certain countries.

The key points of these documents are summarized below.

The BIS policy statement, Controls that May Apply to Advanced Computing Integrated Circuits (IC) and Other Commodities Used to Train AI Models, (herein after referred to May 13 AI Policy Statement) requires exporters and re-exporters to obtain a BIS license to export, reexport, or transfer a commodity classified under Export Control Classification Numbers (ECCN) 3A090.a, 4A090.a and .z items in Categories 3, 4, and 5, e.g. 5A992.z, when there is “knowledge[1]” that the commodity will be used in an AI model that will further the use of WMDs or military intelligence activities in a D:5 country, or for or on behalf of an entity headquartered in a D:5 country.This license requirement applies to U.S. persons that provide any support or performs any contract, service, or employment, when there is “knowledge” that the activities and services will be used for or may assist the training of AI models for or on behalf of parties headquartered in D:5 countries (including China) or Macau.Exporters and re-exporters should presume a policy of denial consistent with policies stated in Part 744.6 – Restriction on Specific Activities of “U.S. Persons”; Part 744.22 - Restrictions on Export, Reexports, and Transfers to certain Military-Intelligence End Users; and Part 744.23, “Supercomputer,” “Advanced - Node Integrated Circuits,” and Semiconductor Manufacturing Equipment End Use Controls, of the Export Administration Regulations (EAR) for any D:5 country.
In its guidance document, Industry Guidance to Prevent Diversion of Advanced Computing Integrated Circuits, BIS provided to exporters and reexporters AI-oriented behavioral and transactional red flags that will trigger a license under the May 13 AI Policy Statement when not mitigated. These red flags add to the “Know Your Customer” Guidance and Red Flags published in Supplement No. 3 to Part 732 of the EAR.

Included with this guidance are due diligence actions required for vetting companies involved in the use or export of AI ICs to destinations outside country Group A:1.

In the second guidance document, Guidance on Application of General Prohibition 10 (GP10) to People’s Republic of China (PRC) Advanced-Computing Integrated Circuits (ICs), BIS clarified that it is a violation of GP10 for any company, including foreign companies, to use Chinese-produced ICs that meet the Advanced IC performance criteria of ECCN 3A090. The guidance included a non-exhaustive illustrative list of three Huawei ICs (i.e. Ascend 910B, 910C, and 910D) subject to GP10 and clarified that boards, servers, or assemblies, whether or not included in the list, are subject to the prohibitions.

This latest knowledge-based end user and end use control and the related due diligence actions, such as evaluating a customer’s ownership structure, adds to the list of other knowledge-based end user and end use restrictions in Part 744 that companies must address when doing business internationally.

These requirements and those under consideration by BIS, such as implementing a 50% ownership similar to one imposed by the Office of Foreign Asset Controls (OFAC) and proposed rules that will expand the scope of intelligence gathering restrictions, require a company to continuously evaluate its compliance program to ensure that it evolves with regulatory changes, as well as those within the company, to prevent violations under the EAR.

We recommend that companies - even those that are not affected by this new requirement - review their compliance programs to ensure it includes a robust end user and end use screening process that reviews transactions against the denied and restricted party lists and the Parts 744 and 746 controls. The process should include methodologies for collecting end user and end use information, as well as for red flag identification with increasing levels of due diligence and risk mitigation that matches the identified risk level. BIS has stated recently that it expects companies to be derisking high risk transactions as described in the various guidance documents and in the EAR and will penalize companies that ignore red flags.

Companies should assess whether their screening tools used for denied and restricted party screening screens the parties to the transaction against relevant lists. The relevant list extends beyond the lists specified under the EAR and include, as stated in the guidance, the Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals (SDN) List, or the U.S. Department of State’s Statutorily Debarred Parties List. In practice, the screening lists should include all the lists administered by OFAC and the DoS. As part of assessment, companies should ensure their screening tools and processes rescreens entities against updates to the lists and flags to responsible employees any open transactions involving a potential match.

With the increasing likelihood that BIS will implement a 50% ownership rule, companies must now consider enhancing their screening process to include an evaluation of an entity’s ownership structure and relevant close affiliations. This is necessary to determine whether the entity is 50% or more owned by a party on the Entity List or other restricted party lists that could prohibit the transaction or trigger a license requirement under the EAR.

Evaluating a company’s ownership structure and potential connections to restricted or sanctioned parties may be supported through ownership research services provided by Kharon, Dow Jones, and Dun & Bradstreet. Additional sources include investor reports, open-sourced platforms (e.g. OpenSanctions.org, and China Defence University Tracker), and general internet searches. Each has its strengths and limitations and should be used to augment traditional screening tools.

Finally, the review should evaluate whether the compliance program provides ongoing training to the employees responsible for screening transactions. Training should include update on regulatory changes, effective use of the screening tools and techniques for researching an entity’s ownership, and changes in the company’s activities (e.g. introduction of new productions or markets) that could subject the activity under existing proposed rules.

As export control regulations continue to evolve and government regulators place greater emphasis on companies to know their customers and to mitigate risk of diversion, companies that fail to regularly review and update their compliance program expose themselves to significant penalties.

A robust end user and end use screening process is one element of a compliance program.

The article Does Your Export Compliance Program Pass Muster? highlights essential elements of an effective compliance program and challenges that companies may face when implementing a program. FD Associates has the expertise and experience to navigate these challenges and can support your company with targeted solutions, such as enhancing your end user and end use screening processes or developing a compliance program tailored to your company.

[1] Knowledge. Knowledge of a circumstance (the term may be a variant, such as "know," "reason to know," or "reason to believe") includes not only positive knowledge that the circumstance exists or is substantially certain to occur, but also an awareness of a high probability of its existence or future occurrence. Such awareness is inferred from evidence of the conscious disregard of facts known to a person and is also inferred from a person's willful avoidance of facts.

Advanced Computing IC Controls – Impacts On Company Compliance Programs Read More »

JUNE 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through June 30, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and persons denied export privileges by the United States Government.

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

REGULATORY UPDATES

President

Providing For The Revocation Of Syria Sanctions

June 30, 2025: By the authority vested in President Trump by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (Public Law 108-175) (Syria Accountability Act), the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (Public Law 102-182, title III) (CBW Act), the Caesar Syria Civilian Protection Act of 2019, as amended (22 U.S.C. 8791 note) (Caesar Act), the Illicit Captagon Trafficking Suppression Act of 2023 (Public Law 118-50, div. P), and section 301 of title 3, United States Code, it is hereby ordered:

Section 1. Background. The United States is committed to supporting a Syria that is stable, unified, and at peace with itself and its neighbors. A united Syria that does not offer a safe haven for terrorist organizations and ensures the security of its religious and ethnic minorities will support regional security and prosperity. The Secretary of State and the Secretary of the Treasury have taken initial steps towards this goal through the issuance on May 23, 2025, of General License 25 and a waiver of sanctions under the Caesar Act.

Sec. 2. Policy. It is the policy of the United States to recognize that circumstances that gave rise to the actions taken in the Executive Orders described in section 3(a) of this order, related to the policies and actions of the former regime of Bashar al-Assad, have been transformed by developments over the past 6 months, including the positive actions taken by the new Syrian government under President Ahmed al-Sharaa. This order supports United States national security and foreign policy goals by directing additional actions, including the removal of sanctions on Syria, the issuance of waivers that permit the relaxation of export controls and other restrictions on Syria, and other actions to be taken by the Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce, as well as by other executive departments and agencies (agencies) of the United States, without providing relief to ISIS or other terrorist organizations, human rights abusers, those linked to chemical weapons or proliferation-related activities, or other persons that threaten the peace, security, or stability of the United States, Syria, and its neighbors.

Sec. 3. Revocation of Syria Sanctions. (a) Effective July 1, 2025, President Trump hereby terminates the national emergency declared in Executive Order 13338 of May 11, 2004 (Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria), and revoke that order, as well as Executive Order 13399 of April 25, 2006 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria), Executive Order 13460 of February 13, 2008 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria), Executive Order 13572 of April 29, 2011 (Blocking Property of Certain Persons with Respect to Human Rights Abuses in Syria), Executive Order 13573 of May 18, 2011 (Blocking Property of Senior Officials of the Government of Syria), and Executive Order 13582 of August 17, 2011 (Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria).
(b) Pursuant to section 202(a) of the NEA (50 U.S.C. 1622(a)), termination of the national emergency declared in Executive Order 13338, as modified in scope and relied upon for additional steps taken in Executive Order 13399, Executive Order 13460, Executive Order 13572, Executive Order 13573, and Executive Order 13582 shall not affect any action taken or pending proceeding not finally concluded or determined as of July 1, 2025, any action or proceeding based on any act committed prior to July 1, 2025, or any rights or duties that matured or penalties that were incurred prior to July 1, 2025.

Sec. 4. Accountability for the Former Regime of Bashar al‑Assad. President Trump finds that additional steps must be taken to ensure meaningful accountability for perpetrators of war crimes, human rights violations and abuses, and the proliferation of narcotics trafficking networks in and in relation to Syria during the former regime of Bashar al-Assad and by those associated with it. Perpetrators of such actions threaten to undermine peace, security, and stability in the region, and thereby constitute an unusual and extraordinary threat to the national security and foreign policy of the United States.

President Trump hereby expands the scope of the national emergency declared in Executive Order 13894 of October 14, 2019 (Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria), as amended in and relied on for additional steps taken in Executive Order 14142 of January 15, 2025 (Taking Additional Steps With Respect to the Situation in Syria), to deal with that threat, and accordingly further amend Executive Order 13894 by:

(i) striking section 1(a) and inserting, in lieu thereof, the following:
“Section 1. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in:

any person determined by the Secretary of the Treasury, in consultation with the Secretary of State:

(A) to be responsible for or complicit in, or to have directly or indirectly engaged in, or attempted to engage in, any of the following in or in relation to Syria:

actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria; or
the commission of serious human rights abuse;

(B) to be a former government official of the former regime of Bashar al-Assad or a person who acted for or on behalf of such an official;

(C) to have engaged in, or attempted to engage in, activities or transactions that have materially contributed to, or pose a significant risk of materially contributing to, the illicit production and international illicit proliferation of captagon;

(D) to be responsible for or complicit in, to have directly or indirectly engaged in, or to be responsible for ordering, controlling, or otherwise directing, instances in which a United States national ((i) as defined in 8 U.S.C. 1101(a)(22) or 8 U.S.C. 1408, or (ii) a lawful permanent resident with significant ties to the United States) went missing in Syria during the former regime of Bashar al-Assad;
(E) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of:

(1) the former regime of Bashar al-Assad;

(2) any activity described in subsections (a)(i)(A)–(a)(i)(D) of this section; or

(3) any person whose property and interests in property are blocked pursuant to this order;

(F) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order; or

(G) to be an adult family member of a person designated under subsections (a)(i)(A)–(a)(i)(D) of this section.”; and

(ii) striking section 2(a) and inserting, in lieu thereof, the following:
“Sec. 2. (a) The Secretary of State, in consultation with the Secretary of the Treasury and other officials of the United States Government as appropriate, is hereby authorized to impose on a foreign person any of the sanctions described in subsections (b) and (c) of this section, upon determining that the person, on or after the date of this order:

is responsible for or complicit in, has directly or indirectly engaged in, or attempted to engage in, or financed the obstruction, disruption, or prevention of efforts to promote a Syria that is stable, unified, and at peace with itself and its neighbors, including:

(A) the convening and conduct of a credible and inclusive Syrian-led constitutional process;

(B) the preparation for and conduct of supervised elections, pursuant to the new constitution, that are free and fair and to the highest international standards of transparency and accountability; or

(C) the development of a Syrian government that is representative and reflects the will of the Syrian people;
(ii) is an adult family member of a person designated under subsection (a)(i) of this section; or
(iii) is responsible for or complicit in, or has directly or indirectly engaged in, or attempted to engage in, the expropriation of property, including real property, for personal gain or political purposes in Syria.”

(b) President Trump additionally amends Executive Order 13606 of April 22, 2012 (Blocking the Property and Suspending Entry into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria Via Information Technology), by removing the following text from the preamble: “Executive Order 13338 of May 11, 2004, as modified in scope and relied upon for additional steps in subsequent Executive Orders” and replacing it with: “Executive Order 13894 of October 14, 2019, and relied upon for additional steps and further amended in subsequent Executive Orders.”

Sec. 5. Caesar Act. The Secretary of State, in consultation with the Secretary of the Treasury, shall examine whether the criteria set forth in section 7431(a) of the Caesar Act have been met, and on the basis of that examination may, pursuant to the Presidential Memorandum of March 31, 2020 (Delegation of Certain Functions and Authorities Under the National Defense Authorization Act for Fiscal Year 2020), suspend in whole or in part the imposition of sanctions otherwise required under the Caesar Act. If the Secretary of State determines to suspend in whole or in part the imposition of such sanctions, the Secretary of State, in consultation with the Secretary of the Treasury, shall provide the briefing to the appropriate congressional committees required by section 7431(b) of the Caesar Act within 30 days of such determination. Further, the Secretary of State, in consultation with the Secretary of the Treasury, shall continue to review the situation in Syria, and if the Secretary of State, in consultation with the Secretary of the Treasury, determines that the criteria set forth in section 7431(a) are no longer met, the Secretary of State shall reimpose sanctions.

Sec. 6. Syria Accountability Act. President Trump hereby determines pursuant to section 5(b) of the Syria Accountability Act that it is in the national security interest of the United States to waive the application of subsection (a)(1), with respect to items on the Commerce Control List (supp. No. 1 to 15 C.F.R. part 774) only, and subsection (a)(2)(A) of the Syria Accountability Act only. The Secretary of State shall submit to the appropriate congressional committees the report required under section 5(b) of that Act.

Sec. 7. CBW Act. (a) Pursuant to section 307(d)(1)(B) of the CBW Act, President Trump hereby determines and certify that there has been a fundamental change in the leadership and policies of the Government of the Syrian Arab Republic. Accordingly, President Trump hereby waives the following sanctions imposed on Syria for the prior use of chemical weapons under the former regime of Bashar al-Assad:

the restriction on foreign assistance under section 307(a)(1) of the CBW Act;

(ii) the restriction on United States Government credit, credit guarantees, or other financial assistance under section 307(a)(4) of the CBW Act;

(iii) the restrictions on the export of national security-sensitive goods and technology under section 307(a)(5) of the CBW Act and on all other goods and technology under section 307(b)(2)(C) of the CBW Act; and

(iv) the restriction on United States banks from making any loan or providing any credit to the Government of Syria under section 307(b)(2)(B) of the CBW Act.

(b) The Secretary of State shall transmit this waiver determination and report as required by sections 307(d)(1)(B) and (d)(2) of the CBW Act to the appropriate congressional committees. This waiver shall be effective 20 days after it has been so transmitted.

Sec. 8. Counterterrorism Designations. (a) The Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, shall take all appropriate action with respect to the designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham and other aliases, as a Foreign Terrorist Organization under 8 U.S.C. 1189 and as a Specially Designated Global Terrorist under 50 U.S.C. 1702 and Executive Order 13224, as well as the designation of Abu Muhammad al Jawlani, commonly known as Ahmed al-Sharaa, as a Specially Designated Global Terrorist.

(b) The Secretary of State shall take all appropriate action to review the designation of Syria as a State Sponsor of Terrorism consistent with section 1754(c) of the National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232; 50 U.S.C. 4813(c)), section 40 of the Arms Export Control Act (Public Law 90-629, as amended; 22 U.S.C. 2780), and section 620A of the Foreign Assistance Act of 1961 (Public Law 87-195, as amended; 22 U.S.C. 2371).

Sec. 9. United Nations. The Secretary of State shall take appropriate steps to advance United States policy objectives at the United Nations to support a Syria that is stable and at peace and to support Syrian efforts to counter terrorism and comply with its responsibilities and obligations concerning weapons of mass destruction, including chemical and biological weapons. The Secretary of State is further directed to explore avenues at the United Nations to provide sanctions relief in support of these objectives.

Sec. 10. Implementation. The Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce, as appropriate, are hereby authorized to take such actions, including adopting rules and regulations, as may be necessary to implement this order. The Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce may, consistent with applicable law, redelegate any of these functions within their respective agencies. The Secretary of State, in consultation with the Secretary of the Treasury, the Secretary of Commerce, and the Secretary of Transportation, as appropriate, is authorized to exercise the functions and authorities conferred upon the President in section 5 of the Syria Accountability Act and to redelegate these functions and authorities consistent with applicable law. All agencies of the United States shall take all appropriate measures within their authority to implement this order, consistent with applicable law.

Sec. 11. General Provisions.

Nothing in this order shall be construed to impair or otherwise affect:

(i) the authority granted by law to an executive department or agency, or the head thereof; or

(ii) the functions of the Director of the Office of Management and Budget relating to budgetary,

administrative, or legislative proposals.

This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

(d) The costs for publication of this order shall be borne by the Department of State.

https://www.whitehouse.gov/presidential-actions/2025/06/providing-for-the-revocation-of-syria-sanctions/

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

Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses

June 11, 2025: 90 Fed. Reg. 23097: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=7aaf6c0a970622900083b3b0f053af61 and

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

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Determinations Regarding Use of Chemical Weapons by Sudan Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991

June 27, 2025: 90 Fed. Reg. 27750: Pursuant to sections 306(a), 307(a), and 307(d) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (22 U.S.C. 5604(a), 5605(a), and 5605(d)), on April 24, 2025 the Senior Official performing the functions of the Under Secretary for Arms Control and International Security determined that the Government of Sudan has used chemical or biological weapons in violation of international law or lethal chemical or biological weapons against its own nationals. As a result, the following sanctions were imposed:

Foreign Assistance: Termination of assistance to Sudan under the Foreign Assistance Act of 1961, except for urgent humanitarian assistance and food or other agricultural commodities or products.

Arms Sales: Termination of (a) sales to Sudan under the Arms Export Control Act of any defense articles, defense services, or design and construction services, and (b) licenses for the export to Sudan of any item on the United States Munitions List.

The Senior Official performing the functions of the Under Secretary for Arms Control and International Security has determined that it is essential to the national security interests of the United States to partially waive the application this sanction to allow for case-by-case adjudication of licenses or other authorizations for defense articles and defense services for entities other than the Government of Sudan on a case-by-case basis for the purposes described pursuant to section 126.1(v) of the International Traffic in Arms Regulations (ITAR).

Arms Sales Financing: Termination of all foreign military financing for Sudan under the Arms Export Control Act.

Denial of United States Government Credit or Other Financial Assistance: Denial to Sudan of any credit, credit guarantees, or other financial assistance by any department, agency, or instrumentality of the United States Government, including the Export-Import Bank of the United States.

Exports of National Security-Sensitive Goods and Technology: Prohibition on the export to Sudan of any goods or technology controlled for National Security (NS) reasons on the Commerce Control List (CCL) established under 50 U.S.C. 4813(a)(1).

The Senior Official performing the functions of the Under Secretary for Arms Control and International Security has determined that it is essential to the national security interests of the United States to waive the application of this sanction in order to allow the authorization of exports or re-exports of NS-controlled goods or technology to Sudan in accordance with the following policies:

License Exceptions: Exports and re-exports of NS-controlled goods or technology on the CCL may be authorized under License Exceptions GOV, ENC, BAG, TMP, RPL, TSU and ACE, as described in 15 CFR part 740.

Safety of Flight: Exports and re-exports of NS-controlled goods or technology may be authorized pursuant to new licenses when necessary for the safety of flight of civil fixed-wing passenger aviation, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.

Deemed Exports/Re-Exports: Exports and re-exports of goods or technology may be authorized pursuant to new licenses for deemed exports and re-exports to Sudanese nationals, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.

Wholly Owned U.S. and Other Foreign Subsidiaries: Exports and re-exports of NS controlled goods or technology may be authorized pursuant to new licenses for exports and re-exports to wholly-owned U.S. and other foreign subsidiaries in Sudan, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.

These measures shall be implemented by the responsible departments and agencies of the United States government and will remain in place for at least one year and until further notice.

www.federalregister.gov/documents/2025/06/27/2025-11896/determinations-regarding-use-of-chemical-weapons-by-sudan-under-the-chemical-and-biological-weapons

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DDTC Name And Address Changes Posted To Website

June 3 through June 13, 2025: 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:

Change in Name of Jacobs Australia Pty Limited to Amentum Australia Proprietary Limited due to merger;
Change in Address of FISBA, LLC from 983 Riverside Street, Portland, ME 04103 to 6 Willey Road, Saco, ME 04072;
Change in Address of GE Aviation Systems North America LLC - Abu Dhabi from Al Hisn, East 6, C5, building Amna Ahmed Mohamed O, Abu Dhabi, United Arab Emirates to Al Hisn, East 6, C5, building Amna Ahmed Mohamed Onwani, 621, Zayet The First St., Al Hisn, Abu Dhabi 20035, United Arab Emirates;
Change in Name of Centum Solutions S.L. to Bertrandt Technology Spain S.L. D due to acquisition.

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DDTC Frequently Asked Questions (FAQs)

Q: What does it mean to be on one of DDTC's lists of debarred parties?

A: Persons subject to statutory or administrative debarment are generally prohibited from participating directly or indirectly in ITAR-controlled activities, such as the export of technical data and other defense articles and the furnishing of defense services for which a license or other approval is required. Also, pursuant to ITAR § 127.1(d), it is a violation for a person with knowledge that another person is ineligible under ITAR § 120.16(c), which includes debarred parties, to, among other things, apply for, obtain, or use an export control document on behalf of a debarred party, or participate in a transaction subject to the ITAR that will benefit a debarred party, without first obtaining DDTC’s approval.

DDTC has specified the consequences of debarment in the ITAR, and the Federal Register Notices announcing the debarment provide further detail regarding the debarment. DDTC does not impose any restrictions on a debarred party’s eligibility to obtain banking services, engage in real estate transactions, purchase automobiles, or participate in any other activity not controlled under the ITAR.

Q: Where can I find or track the status of my registration?

A: Registrations submitted in DECCS can be tracked in the DECCS registration application on the Registration Dashboard page under the “In Progress” or “Active Registration” sections.

It normally takes 30 days on average from the time the registration application is submitted for DDTC to adjudicate your registration. Once the review has been completed and approved, the Registration Dashboard with be updated to show the new status of the registration application. Please refer to What are the Registration Status Definitions? (KB0011498) for details on the various Registration Status Codes.

Q: What is the benefit of citing precedent cases?

A: Citing relevant precedent cases assists the Licensing Officer in reviewing the proposed application by providing license and staffing history. It is requested that the cited precedent be for the same commodity and same end-use/end-user of the proposed application

Q: If I am a U.S. person providing a defense service to a foreign entity, do I need to register with DDTC?

A: That will depend upon whether you are permanently residing in the United States or abroad. Registration is not required if you both physically reside and provide the defense service outside the United States. Under ITAR § 122.1(a), registration is required only for persons who engage in the United States in the business of furnishing defense services or manufacturing, exporting, or temporarily importing defense articles. If at any point you engage in the United States in the business of furnishing defense services (to include remote work/telework), you would be required to register with the Department unless otherwise exempted from the registration requirement as described in ITAR § 122.1(b).

Q: DECCS says that my authorization has been approved but I have not yet received my authorization letter. What do I do?

A: Authorization letters are electronically sent to the to the applicant’s email address as provided in the application. If it has been more than a week since the case closed in DECCS, check your junk mail folder. Authorization letters will come from DDTCPaperCase@state.gov. If after checking your spam folder you find that you still have not received the authorization, email the USPAB Case Status Orgbox at PM-DTCL-USPAB-Status@state.gov.

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Kuwait

June 4, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Kuwait has requested to buy equipment and services related to sustainment support for legacy M1A2 and new M1A2K Abrams main battle tank systems. The following non-MDE items will be included: repair parts; spare parts; replacement materials; and other related elements of logistics and program support. The estimated total cost is $325 million. The principal contractor will be General Dynamics Land Systems, located in Sterling Heights, MI. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4206289/kuwait-m1a2-abrams-main-battle-tank-system-sustainment-support

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DSCA Notifies Congress of Potential FMS Sale To The Netherlands

June 12, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Netherlands has requested to buy two hundred ninety-six (296) AGM-179A Joint Air-to-Ground Missiles (JAGM). The following non-MDE items will also be included: AGM-179 JAGM Captive Air Training Missiles (CATM); Tactical Aviation Ground Munition Program (TAGM) office technical assistance; Security Assistance Management Directorate (SAMD), Joint Attack Munition Systems (JAMS) technical assistance; missile handling training; classified and unclassified publications; spare parts; repair and return; storage; and other related elements of program and logistical support. The estimated total cost is $215 million. The principal contractor will be Lockheed Martin Corporation, located in Orlando, FL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4215271/the-netherlands-joint-air-to-ground-missiles

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DSCA Notifies Congress of Potential FMS Sale To Italy

June 16, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Italy has requested to buy thirty (30) AIM-120D-3 Advanced Medium-Range Air-to-Air Missiles (AMRAAM), forty (40) AIM-120C-8 AMRAAMs, and two (2) AIM-120C-7 AMRAAM guidance sections. The following non-MDE items will also be included: AMRAAM control section spares and containers; spare and repair parts, consumables, accessories, and repair and return support; weapon system support and software; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; U.S. government and contractor engineering, technical, and logistical support services; and other related elements of logistics and program support. The estimated total cost is $211 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4217573/italy-advanced-medium-range-air-to-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Australia

June 16, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Australia has requested to buy the following equipment and services related to sustainment of its F/A-18F Super Hornet and EA-18G Growler aircraft fleet: sixty (60) Global Lightning – Joint Tactical Terminal – Transceivers (JTT-X); forty (40) Advanced Electronic Warfare systems; and twenty-four (24) Next Generation Electronic Attack Units (NGEAU). The following non-MDE items will also be included: AN/PYQ-10C Simple Key Loaders; Inline Network Encryptors; AN/ALE-47 electronic warfare countermeasures systems (common carriage); Joint Mission Planning System (JMPS) software; aircraft spares and repair parts; other support equipment; software and hardware updates and development; system configuration upgrades; avionics software support; aircraft armament equipment; Foreign Liaison Officer support; technical data; engineering change proposals; engine component improvements; training and training equipment; training aids, devices, and spares; flight test services; transportation costs; system integration and testing; software development and integration; tools and test 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 $2.0 billion. The principal contractor will be The Boeing Company, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4217508/australia-fa-18f-and-ea-18g-sustainment-support

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DSCA Notifies Congress of Potential FMS Sale To Israel

June 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Israel has requested to buy three thousand eight hundred forty-five (3,845) KMU-558B/B Joint Direct Attack Munition (JDAM) guidance kits for the BLU-109 bomb body and three thousand two hundred eighty (3,280) KMU-572 F/B JDAM guidance kits for the MK 82 bomb body. The following non-MDE items will also be included: U.S. government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $510 million. The principal contractor will be The Boeing Company, located in St. Charles, MO. Part of the JDAM guidance kit requirement may be transferred from U.S. government stock. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4230375/israel-munitions-guidance-kits-and-munitions-support

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U.S. Census Bureau

How to Resolve Common AES Response Messages

June 17, 2025:

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: 504

Narrative: License Code Unknown

Severity: Fatal

Reason: The License Code reported is not valid in AES.

Resolution: The License Code/License Exemption Code must be reported on each EEI. Valid License Codes reportable in AES can be found in Appendix F – License and License Exemption Type Codes and Reporting Guidelines.

Verify the License Code/License Exemption Code, 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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Alcohol and Tobacco Tax and Trade Bureau (TTB) removed from the Automated Export System Trade Interface Requirements (AESTIR)

June 25, 2025:

CSMS # 65439382 - Alcohol and Tobacco Tax and Trade Bureau (TTB) removed from the Automated Export System Trade Interface Requirements (AESTIR)

The Alcohol and Tobacco Tax and Trade Bureau (TTB) has inactivated its Partner Government Agency (PGA) Export Message Set. References for TTB have been removed from Appendices Q and X of the Automated Export System Trade Interface Requirement (AESTIR). Previously, the submission of TTB PGA export message set had been voluntary. TTB discontinued collection of this data as a deregulatory action.

Referenced appendices can be viewed here: https://www.cbp.gov/trade/aes/aestir/appendices

LATEST SANCTIONS FINES & PENALTIES

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

Fines and Penalties

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

June 9, 2025: A 22-count indictment was unsealed charging Iurii Gugnin, also known as Iurii Mashukov and George Goognin, 38, a resident of New York and citizen of Russia, with various offenses related to using his cryptocurrency company Evita to funnel more than $500 million of overseas payments through U.S. banks and cryptocurrency exchanges while hiding the source and purpose of the transactions.

According to court documents, Gugnin is charged with wire and bank fraud, conspiracy to defraud the United States, violation of the International Emergency Economic Powers Act (IEEPA), operating an unlicensed money transmitting business, failing to implement an effective anti-money laundering compliance program, failing to file suspicious activity reports, money laundering, and related conspiracy charges. Gugnin was arrested and arraigned in New York.

If convicted, Gugnin faces a maximum penalty of 30 years in prison for each count of bank fraud; a maximum penalty of 20 years in prison for each of the wire fraud, IEEPA, money laundering, and related conspiracy counts; a maximum penalty of 10 years in prison for failure to implement an effective anti-money laundering program and failure to file suspicious activity reports; and a maximum penalty of five years in prison for conspiracy to defraud the United States and operating an unlicensed money transmitting business.

https://www.justice.gov/opa/pr/founder-cryptocurrency-payment-company-charged-evading-sanctions-and-export-controls

https://media.bis.gov/news-updates

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June 10, 2025: An illegal alien from China pleaded guilty to federal criminal charges for illegally exporting firearms, ammunition and other military items to North Korea by concealing them inside shipping containers that departed from the Port of Long Beach, California, and for committing this crime at the direction of North Korean government officials, who wired him approximately $2 million for his efforts.

Shenghua Wen, 42, of Ontario, California, pleaded guilty to one count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA) and one count of acting as an illegal agent of a foreign government. Wen has been in federal custody since his arrest in December 2024.

Wen faces a maximum penalty of 20 years in prison on the count of violating the IEEPA and a maximum penalty of 10 years in prison on the count of acting as an illegal agent of a foreign government. Sentencing is scheduled for Aug. 18. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

https://www.justice.gov/opa/pr/chinese-national-pleads-guilty-acting-direction-north-korea-export-firearms-ammo-and

https://media.bis.gov/news-updates

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June 23, 2025: The Bureau of Industry and Security, U.S. Department of Commerce (“BIS”), has notified Unicat Catalyst Technologies, LLC, of Alvin, Texas, as successor to Unicat Catalyst Technologies, Inc., (“Unicat”), of its intention to initiate an administrative proceeding against Unicat pursuant to Section 766.3 of the Export Administration Regulations (the “Regulations”), through the issuance of a Proposed Charging Letter to Unicat that alleges that Unicat committed three violations of the Regulations.

Specifically: On three occasions between on or about October 2017 through on or about September 2020, Unicat Catalyst Technologies, Inc. (“Legacy Unicat”), which was acquired by a private equity firm and converted into the successor entity Unicat, engaged in conduct prohibited by the Regulations when it sold and arranged for the export of items subject to the EAR and designated EAR99, specifically, catalysts, valued at $391,182.78, with knowledge that these items were intended for export to Iran without the requisite license or other authorization. By arranging for the export of the items without the required license or other authorization, Legacy Unicat committed three violations of Section 764.2(e) of the Regulations.

https://media.bis.gov/press-release/bis-reaches-administrative-enforcement-settlement-unicat-catalyst-technologies-llc-order

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Sanctions

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

June 5, 2025: The United States sanctioned four individuals, currently serving as judges of the International Criminal Court (ICC). It reflects the seriousness of the threat we face from the ICC’s politicization and abuse of power. The Department of State’s designations are made pursuant to Executive Order (E.O.) 14203, which authorizes sanctions on foreign persons engaged in certain efforts by the ICC and aims to impose tangible and significant consequences on those directly engaged in the ICC’s transgressions against the United States and Israel.

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

Alapini Gansou, Reine Adelaide Sophie of the Netherlands;
Bossa, Solomy Balungi of the Netherlands;
Hohler, Beti of the Netherlands; and
Ibanez Carranza, Luz Del Carmen of the Netherlands.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued ICC-related General License 1, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on June 5, 2025," ICC-related General License 2, "Authorizing the Provision of Certain Legal Services;" ICC-related General License 3, "Authorizing Payments for Legal Services From Funds Originating Outside the United States;" ICC-related General License 4, "Authorizing Emergency Medical Services;" ICC-related General License 5, "Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized;" ICC-related General License 6, "Authorizing Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Personal, Non-Commercial Use;" and ICC-related General License 7, "Official Business of the United States Government."

GENERAL LICENSE NO. 1: “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on June 5, 2025”

(a) All transactions prohibited by Executive Order (E.O.) 14203 that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern daylight time, July 8, 2025, provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States:

(1) Solomy Balungi Bossa;

(2) Luz Del Carmen Ibanez Carranza;

(3) Reine Adelaide Sophie Alapini Gansou;

(4) Beti Hohler; or

(5) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

GENERAL LICENSE NO. 2: “Authorizing the Provision of Certain Legal Services”

(a) The provision of the following legal services to or on behalf of persons whose property and interests in property are blocked pursuant to Executive Order (E.O.) 14203 is authorized, provided that any receipt of payment of professional fees and reimbursement of incurred expenses must be authorized pursuant to General License 3 under E.O. 14203, which authorizes certain payments for legal services from funds originating outside the United States; via specific license; or otherwise pursuant to E.O. 14203:

(1) Provision of legal advice and counseling on the requirements of and compliance with the laws of the United States or any jurisdiction within the United States, provided that such advice and counseling are not provided to facilitate transactions in violation of E.O. 14023;

(2) Representation of persons named as defendants in or otherwise made parties to legal, arbitration, or administrative proceedings before any U.S. federal, state, or local court or agency;

(3) Initiation and conduct of legal, arbitration, or administrative proceedings before any U.S. federal, state, or local court or agency;

(4) Representation of persons before any U.S. federal, state, or local court or agency with respect to the imposition, administration, or enforcement of U.S. sanctions against such persons; and

(5) Provision of legal services in any other context in which prevailing U.S. law requires access to legal counsel at public expense.

(b) The provision of any other legal services to or on behalf of persons whose property and interests in property are blocked pursuant to E.O. 14203, not otherwise authorized pursuant to a general license issued pursuant to E.O. 14203, requires the issuance of a specific license.

(c) U.S. persons do not need to obtain specific authorization to provide related services, such as making filings and providing other administrative services, that are ordinarily incident to the provision of services authorized by paragraph (a) of this general license. Additionally, U.S. persons who provide services authorized by paragraph (a) of this general license do not need to obtain specific authorization to contract for related services that are ordinarily incident to the provision of those legal services, such as those provided by private investigators or expert witnesses, or to pay for such services.

(d) Entry into a settlement agreement or the enforcement of any lien, judgment, arbitral award, decree, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to E.O. 14203 is prohibited unless licensed pursuant to E.O. 14203.

GENERAL LICENSE NO. 3: “Authorizing Payments for Legal Services From Funds Originating Outside the United States”

(a)(1) Professional fees and incurred expenses. Receipt of payment of professional fees and reimbursement of incurred expenses for the provision of legal services authorized pursuant to General License 2 under Executive Order (E.O.) 14203 to or on behalf of any person whose property and interests in property are blocked pursuant to E.O. 14203 is authorized from funds originating outside the United States, provided that the funds do not originate from:

(i) A source within the United States;

(ii) Any source, wherever located, within the possession or control of a U.S. person; or

(iii) Any individual or entity, other than the person on whose behalf the legal services authorized pursuant to General License 2 under E.O. 14203 are to be provided, whose property and interests in property are blocked pursuant to E.O. 14203, any part of 31 CFR chapter V, or any other Executive order or statute.

(2) Nothing in paragraph (a) authorizes payments for legal services using funds in which any other person whose property and interests in property are blocked pursuant to E.O. 14203, any part of 31 CFR chapter V, or any other Executive order or statute has an interest.

(b) Records. U.S. persons who receive payments pursuant to paragraph (a) of this general license must retain for 10 years from the date of the relevant payment, and furnish to OFAC on demand, a record that specifies the following for each payment:

(1) The individual or entity from whom the funds originated and the amount of funds received; and (2) If applicable:

(i) The names of any individuals or entities providing related services to the U.S. person receiving payment in connection with authorized legal services, such as private investigators or expert witnesses;

(ii) A general description of the services provided; and

(iii) The amount of funds paid in connection with such services

GENERAL LICENSE NO. 4: “Authorizing Emergency Medical Services”

The provision and receipt of nonscheduled emergency medical services that are prohibited by Executive Order 14203 are authorized.

GENERAL LICENSE NO. 5: “Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized”

(a) A U.S. financial institution is authorized to debit any account blocked pursuant to Executive Order (E.O.) 14203 held at that financial institution in payment or reimbursement for normal service charges owed it by the owner of that blocked account.

Note to paragraph (a). As used in this general license, the term normal service charges shall include charges in payment or reimbursement for interest due; cable, telegraph, internet, or telephone charges; postage costs; custody fees; small adjustment charges to correct bookkeeping errors; and, but not by way of limitation, minimum balance charges, notary and protest fees, and charges for reference books, photocopies, credit reports, transcripts of statements, registered mail, insurance, stationery and supplies, and other similar items.

(b) Any payment of funds or transfer of credit in which a person whose property and interests in property are blocked pursuant to E.O. 14203 has any interest that comes within the possession or control of a U.S. financial institution must be blocked in an account on the books of that financial institution. A transfer of funds or credit by a U.S. financial institution between blocked accounts in its branches or offices is authorized, provided that no transfer is made from an account within the United States to an account held outside the United States, and further provided that a transfer from a blocked account may be made only to another blocked account held in the same name.

Note to paragraph (b). Such transfers must be reported to the Office of Foreign Assets Control consistent with § 501.603 of the Reporting, Procedures and Penalties Regulations, 31 CFR part 501.

GENERAL LICENSE NO. 6: “Authorizing Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Personal, Non-Commercial Use”

(a) All transactions prohibited by Executive Order (E.O.) 14203 that are related to the provision, directly or indirectly, of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to an individual whose property and interests in property are blocked pursuant to E.O. 14203 are authorized, provided the items are in quantities consistent with personal, non-commercial use.

(b) For the purposes of this general license, agricultural commodities, medicine, and medical devices are defined as follows:

(1) Agricultural commodities. For the purposes of this general license, agricultural commodities are:

Products that fall within the term “agricultural commodity” as defined in section 102 of the Agricultural Trade Act of 1978 (7 U.S.C. 5602); and (
ii) That are intended for ultimate use as:

(A) Food for humans (including raw, processed, and packaged foods; live animals; vitamins and minerals; food additives or supplements; and bottled drinking water) or animals (including animal feeds);

(B) Seeds for food crops;

(D) Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food animals.

(2) Medicine. For the purposes of this general license, medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).

(3) Medical devices. For the purposes of this general license, a medical device is an item that falls within the definition of “device” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).

Note 1 to General License 6. This general license does not relieve any person authorized thereunder from complying with any other applicable laws or regulations

GENERAL LICENSE NO. 7: “Official Business of the United States Government”

All transactions prohibited by Executive Order (E.O.) 14203 that are for the conduct of the official business of the United States Government by employees, grantees, or contractors thereof are authorized.

Note to General License No. 7. See also section 7 of E.O. 14203, which exempts transactions for the conduct of the official business of the Federal Government by employees, grantees, or contractors thereof.

https://ofac.treasury.gov/recent-actions/20250605

https://www.state.gov/imposing-sanctions-in-response-to-the-iccs-illegitimate-actions-targeting-the-united-states-and-israel/

https://ofac.treasury.gov/media/934326/download?inline

https://ofac.treasury.gov/media/934331/download?inline

https://ofac.treasury.gov/media/934336/download?inline

https://ofac.treasury.gov/media/934341/download?inline

https://ofac.treasury.gov/media/934346/download?inline

https://ofac.treasury.gov/media/934351/download?inline and

https://ofac.treasury.gov/media/934356/download?inline

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June 5, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four Guyanese nationals and two Colombian nationals responsible for trafficking tons of cocaine from South America to the United States, Europe, and the Caribbean. These sanctions target drug traffickers utilizing boats and narco-subs to traffic ton-quantities of cocaine, along with an alleged corrupt Guyanese law enforcement official. The sanctions also target individuals that are operating covert airstrips to traffic drugs via aircraft. For decades, reported corrupt actors have used Guyana as a transshipment point for the movement of drugs from South America to the United States, with Mexican drug cartels also maintaining a presence in the region. International cocaine trafficking remains a serious threat to the United States, as the substantial profits generated from these sales continue to fund and strengthen cartel operations.

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

Cromwell, Mark of Guyana;
Daby Jr., Paul of Guyana;
Duncan, Randolph of Guyana;
Salazar Gutierrez, Manuel of Colombia;
Sanchez Vallejo, Yeison Andres of Colombia; and
Sawh, Himnauth of Guyana.

https://ofac.treasury.gov/recent-actions/20250605

https://home.treasury.gov/news/press-releases/sb0156 and

https://ofac.treasury.gov/media/934316/download?inline=

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June 6, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated over 30 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, who have collectively laundered billions of dollars through the international financial system via Iranian exchange houses and foreign front companies under their control as part of Iran’s “shadow banking” network. The regime leverages this network to evade sanctions and move money from its oil and petrochemical sales, which help the regime fund its nuclear and missile programs and support its terrorist proxies.

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

Kuhi, Fatemah Sarlak of Iran;
Meshkat, Farahnaz of Iran;
Shetaban, Hossein of Iran;
Soltanizadeh, Parviz of Iran;
Zarringhalam, Fazlolah of Iran;
Zarringhalam, Mansour of Iran;
Zarringhalam, Mitra of Iran;
Zarringhalam, Nasser of Iran;
Zarringhalam, Pouria of Iran; and
Zhang, Yu of China.

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

Ace Petrochem Fze of the United Arab Emirates;
Bstsheh HK Limited of China;
Chungling HK Limited of China;
Fitage Limited of China;
Golden Pen General Trading L.L.C. of the United Arab Emirates;
Gutown Trade Limited of China;
Hero Companion Limited of China;
S Serenity Trading FZE of the United Arab Emirates;
Kimia Sadr Pasargad Company of Iran;
Kinlere Trading Limited of China;
Konosag Trading Limited of China;
Lastsix Trading Limited of China;
Magical Eagle Limited of China;
Mansour Zarrin Ghalam and Partners Company of Iran;
Marlena Trading Limited of China;
Moderate General Trading L.L.C. of the United Arab Emirates;
Nasser Zarrin Ghalam and Partners Company of Iran;
Plzcome Limited of China;
Prettyandy Trading Limited of China;
Profu Company Limited of China;
Questano HK Limited of China;
Saldiege Trading Limited of China;
Wide Vision General Trading L.L.C. of China;
Xia Trading Limited of China;
Yiminai Autoparts Trading Limited of China;
Zarrin Ghalam and Partners Company of Iran; and
Zarrin Tehran Investment Company of Iran.

https://home.treasury.gov/news/press-releases/sb0159

https://ofac.treasury.gov/recent-actions/20250606

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June 9, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Los Chapitos, a powerful faction of the Mexico-based Sinaloa Cartel that facilitates illicit fentanyl trafficking and production. Los Chapitos-controlled laboratories are responsible for introducing fentanyl in counterfeit pills manufactured by the Sinaloa Cartel and trafficked to the United States. Gunmen linked to the Sinaloa Cartel were also involved in the October 18, 2024 killing of former U.S. Marine Nicholas Quets in Sonora, Mexico.

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

Barraza Pablos, Victor Manuel of Mexico;
Nunez Rios, Jose Raul of Mexico; and
Urias Vazquez, Sheila Paola of Mexico.

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

Beach y Marina, S.A. DE C.V. of Mexico;
Carpe Diem Spa of Mexico;
Club Playa Real, S.A. DE C.V. of Mexico;
Comercializadora Copado, S.A. DE C.V. of Mexico;
Eco Campestres Ultra, S.A.P.I. of Mexico;
IMB 24 Siete, S.A. DE C.V of Mexico;
Los Chapitos of Mexico;
Mkt 24 Siete, S.A. DE C.V of Mexico;
Mue Renta y Venta De Vestidos of Mexico;
Poyecta Interna, S.A. DE C.V. of Mexico; and
Sea WA Beach Club, S.A. DE C.V. of Mexico.

https://home.treasury.gov/news/press-releases/sb0161 and

https://ofac.treasury.gov/recent-actions/20250609

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June 10, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five individuals, and five sham charities located abroad that are prominent financial supporters of Hamas’s Military Wing and its terrorist activities. The individuals and entities sanctioned are responsible for funding Hamas’s Military Wing under the pretense of conducting humanitarian work, both internationally and in Gaza. Treasury also targeted a separate fraudulent charity linked to the Popular Front for the Liberation of Palestine (PFLP).

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

Abu Marei, Muhammad Sami Muhammad of Palestine;
Abu Rashed, Amin of the Netherlands;
Arawi, Zeki Abduallah Ibrahim of Turkey;
Brahimi, Ahmed of Algeria; and
Rashed, Israa Abou of the Netherlands.

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

Addammer Prisoner Support and Human Rights Association of Israel;
Al Weam Charitable Society of Northern Gaza;
Associazone Benefica La Cupola D’oro of Italy;
El Baraka Association For Charitable and Humanitarian Work of Algeria;
Filistin Vakfi of Turkey; and
Israa Charitable Foundation Netherlands of the Netherlands.

https://ofac.treasury.gov/recent-actions/20250610

https://home.treasury.gov/news/press-releases/sb0162

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June 12, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has assessed a $215,988,868 civil monetary penalty against GVA Capital Ltd. of San Francisco, California for violations of OFAC's sanctions against Russia and for related reporting obligations. GVA Capital knowingly managed an investment for sanctioned Russian oligarch Suleiman Kerimov while aware of his blocked status. GVA Capital also failed to comply with an OFAC subpoena during OFAC's investigation into this matter.

The penalty amount reflects OFAC's determination that GVA Capital's conduct was egregious and not voluntarily self-disclosed.

https://ofac.treasury.gov/recent-actions/20250612

https://ofac.treasury.gov/media/934366/download?inline

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June 12, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) made the following additions to its SDN list.

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

Huthele, Nasr Mohsen Ali of Iraq.

The following entity has been added to OFAC’s SDN List:

Kata’ib Al-Imam Ali of Iraq.

https://ofac.treasury.gov/recent-actions/20250612

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June 16, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $3,882,797 settlement with Unicat Catalyst Technologies, LLC (“Unicat”). Unicat, an Alvin, Texas-based company that sells catalyst products, has agreed to settle its potential civil liability for 13 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), and one apparent violation of the Venezuela Sanctions Regulations (VSR) that arose from its provision of catalyst products and consulting services to Iran and its sale of catalysts to a blocked Venezuelan entity. The settlement amount reflects OFAC’s determination that Unicat’s conduct was voluntarily self-disclosed and constituted an egregious case.

https://ofac.treasury.gov/media/934376/download?inline and

https://ofac.treasury.gov/media/934381/download?inline

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June 18, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five Mexico-based leaders of Cartel de Jalisco Nueva Generacion (CJNG). CJNG is a brutally violent cartel responsible for a significant share of fentanyl and other illicit drugs entering the United States. It uses murder as a tactic to intimidate rivals, including sending messages to other cartels through the targeted killings of women. The recent discovery of a CJNG recruitment camp, Izaguirre ranch—which was reportedly used to execute recruits that defy instructions—underscores the cartel’s brutal methods.

The following individual has been added to OFAC’s SDN List:

Ruiz Velasco, Ricardo of Mexico.

https://ofac.treasury.gov/recent-actions/20250618

https://home.treasury.gov/news/press-releases/sb0169

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June 20, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela General License 5S – Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After December 20, 2025.

GENERAL LICENSE NO. 5S: “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After December 20, 2025”

On or after December 20, 2025, 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.

https://ofac.treasury.gov/media/934391/download?inline

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June 20, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took its single largest action to date against Iran-backed Ansarallah, commonly known as the Houthis, targeting four individuals, 12 entities, and two vessels that have imported oil and other illicit goods in support of the terrorist group. This action includes Houthi front companies, their owners, and other key Houthi operatives that generate significant revenue for the group through the sale of oil and other commodities on Yemen’s black market and by engaging in smuggling operations through Houthi-controlled ports. As part of this action, Treasury is also targeting two vessels, as well as their owners and operators, which violated U.S. sanctions by discharging oil derivatives to the Houthis.

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

Al-Washli, Zaid of Yemen;
Dabbash, Abdullah Ahsan Abdullah of Yemen;
Daghsan, Daghsan Ahmed of Yemen; and
Talea, Ali Ahmed Daghsan of Yemen.

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

Abbot Trading Co., Ltd. of Yemen;
Atlantis M. Shipping Co of the Marshall Islands:
Azzahra Establishment for Commerce and Agencies of Yemen;
Best Way Tanker Corp of Moldova;
Black Diamond Petroleum Derivatives of Yemen;
Gasoline Aman Company For Oil Derivatives Imports of Yemen;
Ocean Voyage LLC of Azerbaijan;
Royal Plus Shipping Services and Commercial Agencies of Yemen;
Star Plus Yemen Trading Limited of Yemen;
Tamco Establishment for Oil Derivatives of Yemen;
Yahya Al-Usalli Company for Import Limited of Yemen; and
Yemen Elaph Petroleum Derivatives Import of Yemen.

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

Atlantis MZ (D604003) Crude Oil Tanker Unknown flag; Former Vessel Flag Comoros; MMSI 620800003 (vessel); and
Valente (T8A4170) Crude Oil Tanker Palau flag; MMSI 511100949 (vessel).

https://ofac.treasury.gov/recent-actions/20250620 and

https://home.treasury.gov/news/press-releases/sb0174

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June 20, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated one individual and eight entities, and identifying one vessel as blocked property, for their involvement in the procurement and transshipment of sensitive machinery for Iran’s defense industry. The vessel, SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd, was carrying this machinery for OFAC-designated Rayan Roshd Afzar Company (RRA) and Towse Sanaye Nim Resanaye Tarashe, a company controlled by RRA executives. This action is being taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied the development of missiles and other weapons capabilities and that the Islamic Revolutionary Guard Corps (IRGC) and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities.

The following individual has been added to OFAC’s SDN List:

Zhang, Yanbing of China.

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

Athena Shipping Co Ltd of China;
Dongguan Zanyin Machinery and Equipment Co Ltd of China;
Edisa Dis Ticaret Limited Sirketi of Turkey;
Futech Co Ltd of China;
Shenzhen Xinxin Shipping Co Ltd of China;
Towse Sanaye Nim Resanaye Tarashe of Iran;
Unico Shipping Co Ltd of China; and
V-shipping Pte Ltd of Singapore.

The following vessel has been added to OFAC’s SDN List:

Shun Kai Xing (3E5884) Bulk Carrier Panama flag; MMSI 352003792 (vessel)

https://ofac.treasury.gov/recent-actions/20250620 and

https://home.treasury.gov/news/press-releases/sb0175

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June 24, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Giovanni Vicente Mosquera Serrano (Mosquera Serrano), a fugitive leader of Tren de Aragua (TdA) who is involved in the organization’s drug trafficking and financial operations. TdA is a Foreign Terrorist Organization (FTO) of Venezuelan origin that has launched a campaign of terror throughout the Western Hemisphere, including in the United States, and continues to expand. TdA is involved in illicit drug trade, human smuggling and trafficking, extortion, sexual exploitation of women and children, and money laundering, among other criminal activities.

The following individual has been added to OFAC’s DN List:

Mosquera Serrano, Giovanni Vicente of Venezuela.

https://home.treasury.gov/news/press-releases/sb0178 and

https://ofac.treasury.gov/recent-actions/20250624

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June 27, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 115B, "Authorizing Certain Transactions Related to Civil Nuclear Energy."

In addition, OFAC invites the general public and other Federal agencies to comment on a proposed information collection, as required by the Paperwork Reduction Act of 1995. OFAC is soliciting comments concerning a proposal to add an electronic Sanctions Reconsideration Portal information collection within OFAC’s Reporting, Procedures and Penalties Regulations. This notice is currently available with the Federal Register. Written comments must be received by August 25, 2025, to be assured of consideration.

GENERAL LICENSE NO. 115B: “Authorizing Certain Transactions Related to Civil Nuclear Energy”

(a) All transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to civil nuclear energy are authorized through 12:01 a.m. eastern standard time, December 19, 2025:

(1) Gazprombank Joint Stock Company;

(2) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;

(3) Public Joint Stock Company Bank Financial Corporation Otkritie;

(4) Sovcombank Open Joint Stock Company;

(5) Public Joint Stock Company Sberbank of Russia;

(6) VTB Bank Public Joint Stock Company;

(7) Joint Stock Company Alfa-Bank;

(8) Public Joint Stock Company Rosbank;

(9) Bank Zenit Public Joint Stock Company;

(10) Bank Saint-Petersburg Public Joint Stock Company;

(11) National Clearing Center (NCC);

(12) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or

(13) the Central Bank of the Russian Federation.

(b)For the purposes of this general license, the term “related to civil nuclear energy” means transactions undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024.

Additionally, OFAC has updated several Russia-related Frequently Asked Questions (FAQ 966, FAQ 967, FAQ 978, FAQ 999, FAQ 1010, FAQ 1011, FAQ 1117, FAQ 1182, FAQ 1203, and FAQ 1216).

https://ofac.treasury.gov/media/934396/download?inline

https://ofac.treasury.gov/recent-actions/20250627

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June 30, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action to implement the President’s Executive Order (E.O.) of June 30, 2025, “Providing for the Revocation of Syria Sanctions,” removing U.S. sanctions on Syria in support of the Syrian people and their new government as they rebuild their country and have the opportunity to become a stable and prosperous nation at peace with itself and its neighbors. This E.O. revokes the Executive orders that previously placed comprehensive sanctions on Syria. The E.O. also ensures continued accountability for the Bashar al-Assad regime, expanding the national emergency declared in E.O. 13894 to allow for the continuation of sanctions against Bashar al-Assad, his associates, and other destabilizing regional actors.

On June 30, the President issued an Executive Order "Providing for the Revocation of Syria Sanctions" that removes U.S. sanctions on Syria, effective July 1, 2025. To implement the President's action, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued four new Syria Frequently Asked Questions (FAQs 1220-1223).

FAQ 1220:

Q: How does the Executive Order (E.O.) of June 30, 2025, "Providing for the Revocation of Syria Sanctions," affect OFAC's Syria Sanctions Program?

A: The E.O. of June 30, 2025 removes sanctions on Syria, effective July 1, 2025, while maintaining sanctions on Bashar al-Assad and certain other destabilizing regional actors. Specifically, the E.O. revokes the following six E.O.s that form the foundation of the Syrian Sanctions Program and terminates the national emergency underlying those E.O.s, effective July 1, 2025:

E.O. 13338 of May 11, 2004;
E.O. 13399 of April 25, 2006;
E.O. 13460 of February 13, 2008;
E.O. 13572 of April 29, 2011;
E.O. 13573 of May 18, 2011; and
E.O. 13582 of August 17, 2011.

As a result, as of July 1, 2025, the economic sanctions administered by OFAC that constitute the Syria Sanctions Program are no longer in effect. Persons blocked solely pursuant to these above E.O.s were removed from OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List), and all property and interests in property of such persons are unblocked. OFAC will remove the Syrian Sanctions Regulations from the Code of Federal Regulations. Pending or future OFAC investigations or enforcement actions related to apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025 may still be carried out.

Additionally, the E.O. of June 30, 2025 also preserves and expands OFAC's ability to target Bashar al-Assad and his associates, human rights abusers, captagon drug traffickers, and other destabilizing regional actors by further amending E.O. 13894. Concurrently with the issuance of the E.O. of June 30, 2025, OFAC designated 139 persons who were previously designated under the Syrian Sanctions Program under E.O. 13894, as further amended, or other OFAC authorities.

FAQ 1221:

Q: Can U.S. financial institutions establish relationships with Syrian financial institutions, including the Central Bank of Syria?

A: Yes. All Syrian financial institutions, including the Central Bank of Syria, have been removed from OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List).

Effective July 1, 2025, U.S. persons are not prohibited from providing financial services to Syria, processing payments on behalf of third country financial institutions involving Syrian financial institutions, or conducting transactions with the new Government of Syria and Syrian financial institutions, provided that none of the involved parties are on the SDN List. This includes establishing correspondent banking relationships with Syrian financial institutions. In line with the lifting of Syria sanctions, the Financial Crimes Enforcement Network issued exceptive relief in late May 2025 to permit U.S. financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria. OFAC strongly encourages financial institutions to employ a risk-based sanctions compliance program and update it as appropriate in consideration of new business lines.

FAQ 1222:

Q: Do I need a specific license from OFAC to export or reexport food or medicine to Syria?

A: No. The United States no longer maintains comprehensive sanctions on Syria, effective July 1, 2025, following the issuance of the E.O. of June 30, 2025. You may send U.S.-origin food or medicine to Syria without a specific license from OFAC.

Furthermore, the Department of Commerce maintains jurisdiction over the export of most items to Syria. In the E.O. of June 30, 2025, the President waived requirements to impose certain export controls under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. Please refer to the Department of Commerce for more specifics on export controls involving Syria.

FAQ 1223:

Q: Can persons continue to rely on Syria General License (GL) 25 after the revocation of the Syrian Sanctions Program, on July 1, 2025?

A: Yes. While Syria GL 25 authorizes transactions otherwise prohibited under the Syrian Sanctions Regulations, it also authorizes transactions involving specified persons otherwise prohibited by certain other sanctions programs. To the extent necessary, persons may continue to rely on GL 25 and the related Frequently Asked Questions (FAQs).

https://home.treasury.gov/news/press-releases/sb0183 and

https://ofac.treasury.gov/recent-actions/20250630

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The Department of the Treasury's Office of Foreign Assets Control (OFAC) published regulations to implement Executive Order 14203 of February 26, 2025, "Imposing Sanctions on the International Criminal Court ." These regulations are currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on July 1, 2025.

https://ofac.treasury.gov/recent-actions/20250630_33

JUNE 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

MAY 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through May 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

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

REGULATORY UPDATES

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

Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses

May 2, 2025: 90 Fed. Reg. 17863: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=a69b87859759e21067b1791ad053af95 and

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

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Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses

May 2, 2025: 90 Fed. Reg. 17869: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=6e9b87859759e21067b1791ad053af91 and

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

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DDTC Final Commodity Jurisdiction Determinations Posted to Website

May 5, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between September 12, 2024 through May 5, 2025, on its website at:

https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_kb_article_page&sys_id=6ea6afdcdbc36300529d368d7c96194b

Readers may find these determinations helpful when performing self-classification work.

Model Name	Manufacturer	Description	Final Determination	Final Determination Date
Dominate Virtual Anticipation Network, BUILD.2024.03.05.001	BigBear.ai, LLC	Software that uses automated machine learning to provide anticipatory intelligence and decision support across a multi-domain environment	USML Category XI(b)	9/17/2024
ML-9600, ML-9600W, and ML-9600X Wideband High Frequency (HF) Transceivers; software versions 3.5, 3.6, 3.7, and 3.8	Bronze Bear Communications, Inc., doing business as FlexRadio Systems	Software-defined radios	Seek a CCATS	9/17/2024
Marine Security Design Consulting Services	Ultrasea, Inc	Engineering design and analysis services for surface and subsurface security applications	Scenarios 1-3: Seek a CCATS Scenario 4: Defense service corresponding to the USML category of the related defense articles Scenario 5: Defense service corresponding to the USML category of the related defense articles; USML Category IX(e)(3); and USML Category XVII(a) if using classified technical data not elsewhere described	9/17/2024
AVRA Suite	Arctos, LLC	Software suite that supports the lifecycle of flight safety analysis for airborne vehicles	Seek a CCATS	9/17/2024
64 Megabit (8 M x 8-Bit) CMOS 3.0 Volt-only Uniform Sector Flash Memory, P/N Am29LV065DU90REI	Spansion, LLC	An unprogrammed flash memory device	Seek a CCATS	9/29/2024
Shock Tube, Model Number C4- 25658-050, Part Number C4- 25658-050	ITT Inc.	Inner tube for a shock absorber	Seek a CCATS	10/1/2024
VT977 Integrated Processor/F PGA System, Model A, Part Number VT977-000- 000-000	Vadatech Inc.	A system that integrates an Advanced RISC Machine (ARM) processor with an unprogrammed fieldprogrammable gate array (FPGA) module	Seek a CCATS	10/1/2024
Rocky Linux, Model Number: Rocky Linux v8.5 and v8.9, Part Number: Rocky Linux Kernel v8.x	Hoonify Technologies Inc.	Open-source software operating system used to deliver the parallel computing software platform called TurbOSTM	Seek a CCATS	10/4/2024
Vulcan Basic Kit, Part Number VU0001, and Vulcan Projectile Combo Kit, Part Number VU0093	Alford Technologies Ltd.	A versatile, modular, shaped charge designed for use in a variety of Explosive Ordnance Disposal (EOD) operations, that is inert until filled by the user, and projectiles for the shaped charge	Split: USML Category IV(c), Seek a CCATS	10/4/2024
Lenco BearCat Elevated Ramp Armored Vehicle	Lenco Industries, Inc.	Armored vehicle that transports 10-12 occupants and incorporates articulating rapid entry system	USML Category VII(e)	10/22/2024
RECU (Ruggedized Environmental Control Unit)	Mainstream Engineering Corporation	A portable heating, ventilation, and air conditioning (HVAC) system for temporary structures such as tents	EAR99	10/22/2024
Panoramic Night Vision Goggle NVG-105 (without the image intensifier tubes), Model NVG-105 Rev B, Part Number 10011100-1	Aether Optics LLC	NVG system consisting of the full mechanical, electrical, and optical systems (excluding the IITs), battery pack, and helmet mount	EAR99	10/22/2024
ASM 509 Filled Shell Body, part number 01217926	SAAB North America, Inc.	A projectile shell filled with PAX-47 explosives, but doesn’t include the fuze, fin, assembly, or nose cap	USML Category III(d)(4)	10/22/2024
MERLIN-I (Mounted Enhanced RADIAC Long-Range Imaging Networkable - Imager)	H3D, Inc.	An integrable detector and imaging module that is designed for high-resolution spectroscopy and isotope-specific imaging	USML Category XI(a)(4)(i)	10/22/2024
Aluminum Alloy Extrusion for Missile Container, Blueprint for Extrusion	Universal Alloy Corporation	Extrusion that will become a part for a missile storage container/launch tube, and a blueprint for this extrusion	CCL ECCN 9A604.x, CCL ECCN 9E604.a	10/22/2024
Metallic Hose Assembly, part numbers AE1002867H and AE100120H v.A	Danfoss Power Solutions II, LLC	Metallic, pneumatic hose assemblies	USML Category XX(c)	10/25/2024
Bullfrog, Part Number: BF001	Allen Control Systems Inc.	Remote-controlled weapons station	USML Category XII(a)(1)	10/25/2024
GenesisRL, Model 0.1.4	EpiSys Science, Inc.	Software used in video games to produce a top performing automated artificial intelligence (AI) agent by having different AI agents compete against each other	Seek CCATS	10/27/2024
Single Mode Laser Diode Bar Specification Model Number: 05082024/Rev. 1, Part Number 05082024	Forward Photonics	Technical specification for a laser diode bar	USML Category XVIII(g)	10/27/2024
Distributed Spectrum Software Suite, Version Number 0.1	Distributed Spectrum Inc.	Software capable of real-time RF signal detection, classification, and localization	Seek a CCATS	10/27/2024
Thrust Vector Controller Automated Test Equipment (ATE) Mk2, part number 24P-A75-100-001	BAE Systems Australia Limited	Test Equipment for Missile Thrust Vector Controllers	USML Category IV(i) (software), USML Category XI(a)(7) (system prior to production), ECCN 9B604.d (system when in production)	10/27/2024
Model 86, ver. 1.7	Oehler Research, Inc.	Acoustic Scoring System	USML Category IX(a)(1)(ii), USML Category IX(e)(1) (software), and CCL ECCN 0A614.a (sensors)	11/16/2024
Gulfstream model G700 aircraft with J-MUSIC SPS installed and used solely for Very Important Person or Head of State transport, and certain related information and services	General Dynamics Corporation	Aircraft modified to incorporate a Self-Protection Suite (SPS) without the SPS installed; Aircraft incorporating a SPS; Technical data and services necessary for the SPS installation and maintenance; Maintenance, repair, and other services to support continued safe operation of the modified aircraft; Information common to the unmodified G700 and the modified aircraft.	Split Determination: Modified aircraft: USML Category VIII(a)(8) Aircraft with SPS: USML Category VIII(a)(8) Technical data and services directly related to the modifications: USML Category VIII(i); Technical data and services directly related to the installed SPS: USML Category XI(d); Services for the modified aircraft: USML Category VIII(i) for an (a)(8) aircraft; Information common to the civil G700 and the modified aircraft: Seek a CCATS	3/12/2025
RJ45 8-Channel A/B Port Switcher with RS232 ASCII Remote Control and Pushbutton Local Control, Model 7236, Part Number 306236	Electro Standards Laboratory, Inc.	A unit that enables the sharing of two RJ45 (A&B) ports for each of its eight channels, which allows switching for up to eight devices or networks.	EAR99	10/29/2024
Knowledge Service Engine, Model Number: 4.1.2, Part Number: DMI-KSEC-1	Discovery Machine Inc.	Execution framework for AI behavior models	EAR99	11/3/2024
Two-day Simulated Experimentation Course and “Simulation Experimentation,” PowerPoint Presentation, version 5	CogniPlay Dynamics, Inc.	A course that uses simulation for experimentation to advance armed force capabilities in future operational environments, as well as identify new synergies and opportunities	Service: USML Category IX(e)(3) Information: EAR99	11/16/2024
Spectral Beam Combining Grating	Lawrence Livermore National Laboratory (LLNL)	An optical diffraction grating used in a directed energy weapon system	USML Category XVIII(e)	11/16/2024
EZRAM Raman Spectrometer, Model and Version Number EZRAM Plus Rev A, Part Number 12010	SSI LLC	A spectrometer used to identify unknown molecules through their vibration modes	Seek a CCATS	11/16/2024
Model 86, ver. 1.7	Oehler Research, Inc.	Acoustic Scoring System	USML Category IX(a)(1)(ii)	11/16/2024
MAGCOMM	Precision Targeting, LLC	Wireless communication module - very low power, very short range (1 meter) for replacement of wired connections between electronic components	USML Category XI(c)(2) (part number 52000125) Seek a CCATS (part numbers 52000115 and 52000148)	11/21/2024
Vanguard, U.S. Navy Unmanned Surface Vessel, Model Number: Unmanned, USV-3, Part Number: USV - Vessel	Austal USA, LLC	A mid-size autonomous surface vessel	USML Category VI(c)	11/21/2024
Solidtron, part number SP205-01	Excelitas Technologies Corp	Solid-state pulsed power switching thyristor device	USML Category IV(h)(9)	11/28/2024
Filter Electrical Connector, 38999 Series III, part number 21-50D015-35P	Amphenol Corporation	D38999 circular connector with added filter planar array component	USML Category VIII(f)	11/28/2024
MDS-10, Part Number 3130-0002 and MDS-10T, Part Number 3130-0005	WM Industries Inc.	Handheld dual sensor detectors that combine metal detection and ground penetrating radar technologies for the purpose of detecting improvised explosive devices	USML Category XXI(a)	12/19/2024
Markes TT24-7NRT	CUBRC, Inc.	Test data from a commercial product that is a near real-time vapor sampling system for chemicals	Seek a CCATS	11/29/2024
Digital Acquisition Toolset V1.0	Ricardo, Inc.	Software tools designed to establish an enterprise framework for lifecycle digital engineering.	CCL ECCN 5D002.c.1	11/29/2024
Titanium Fire Pump, Part Number: 5773203, Schematic Number: 803-5773203, Technical Manual: S6255-W6-MMA-010	Carver Pump Company	A titanium centrifugal fire pump and its schematic and technical manual	Pump: CCL ECCN 8A609.x Manual: CCL ECCN 8E609.a Schematic: Seek a CCATS	11/29/2024
HALIA, Model Number: Alpha Prototype, Part Number: v2; Hoverfoil Wings	LeVanta Tech Inc.	Sea-launched aerial drone and its Hoverfoil wings	EAR99	11/29/2024
Embedded Field Programmable Gate Array Intellectual Property (eFPGA), Part Number K6N10	QuickLogic	Family of unprogrammed eFPGA IP architecture	Seek a CCATS	11/29/2024
AgileAir-78, Model Number: 78	Oshkosh Corporation	A portable diesel-powered unit designed to provide ground services to military aircraft	CCL ECCN 9B610.a	11/29/2024
BuildOS, Version: 1	Dirac, Inc.	An automated work instruction platform that drafts instructions for hardware assembly	EAR99	11/29/2024
Spherical Bearing, Part Number MLAM4016	NMB (USA) Inc.	A component of the TP400 aircraft propeller used for blade pitch adjustment and feathering	CCL ECCN 9A610.x	12/8/2024
Spherical Bearing, Part Number KNDB22-12/287600	Sargent Aerospace and Defense, LLC	Spherical bearing for an aircraft landing gear	USML Category VIII(h)(1)	12/8/2024
3X3 LSD, Version 1, Part Number HMCS-MK6X-LSD-3X3, and 6X3 LSD, Version 1, Part Number HMCS-MK6X-LSD-6X3	Haivision MCS LLC	Multi-display video walls created by joining multiple display screens together in harsh environments	CCL ECCN 8A609.x	12/8/2024
Arcas Maritime Domain Awareness System	BigBear.ai, LLC	Data analytics software for maritime domain awareness	USML Category XI(b)	12/8/2024
Encore Flight Software, initial release	Odyssey Space Research, LLC	Flight software framework designed for safety critical components in spacecraft and satellites, providing essential functionality for communication, navigation, control, data processing, and other space-related applications	Seek a CCATS	12/8/2024
Composition A-5 Explosive, Model Composition A-5	US Army Armament Research, Development and Engineering Center (ARDEC)	An explosive compound containing RDX	USML Category V(a)(23)	12/8/2024
M2E Acoustic Modem, Part Number M2E-S115	OceanComm Incorporated	Device that provides high-speed wireless connectivity underwater	CCL ECCN 5A001.b.1.a	12/8/2024
Voxaverse, Part Number 1001	10x National Security	Software that provides chat, voice, video, and file sharing in a fully encrypted multi-user environment	CCL ECCN 5D002.c.1	12/8/2024
Aluminum Mirror, Part Number: C1735	Inrad Optics, Inc.	A component of the Scanner Module of the Electro-Optical Observation System (EOOS) for Military Vehicles	USML Category XII(e)(18)	12/11/2024
SignalQ Event Detection, Part Number GEOL-0020	NVRN, LLC d/b/a	A software-only signal intelligence platform that provides event-detection capability that leverages freely associated mobile phones as sensors	USML Category XI(d)	12/11/2024
Integrated Unique Identification (IUID)	Intrinsic Marks International	MIL-STD-130 compliant identification name plates with a range of thicknesses from .003” to .032” and used on the F-35	Seek a CCATS	12/13/2024
DDM4/DD5 Armorers Manual	M. C. Daniel Group Inc.	A manual for armorer certification for the Daniel Defense (DD) DDM4 and DD5 rifle lines.	USML Category I(i)	12/13/2024
1) Technical data for the design of the H225M Flight Simulator, Iteration: January 1, 2018 through December 31, 2020 2) Technical data for the design of the of H225M Flight Simulator, Iteration: January 1, 2021 the present	FlightSafety International, Inc.	Information related to the Design of the H225M Flight Simulator	USML Category IX(e)(1)	12/13/2024
Nitronic 60 High Strength Stainless Bar, Model Number: UNS S21800, ultra high strength, Part Number: A06200050004 (sample PN)	High Performance Alloys Inc.	Material used to make bushings for an aircraft	Seek a CCATS	12/13/2024
Positive Displacement External Gear Coolant Pump, Model GB-P34-DC30B	Micropump, Inc.	Submarine component	USML Category XX(c)	12/13/2024
Air Conditioner, Model A/M32C-10C, Part Number 100502-2	American Turbo Systems	Used with a ground start cart to provide conditioned air to aircraft	Seek a CCATS	12/13/2024
NATO Resilience and Crisis Management Consulting Service, Model Number: CBI-Resilience-Consulting-01 v1.0	Capacity Building International	Consulting services focused on NATO resilience, emergency management, and crisis response.	Seek a CCATS	12/13/2024
High-Temperature Material Characterization System, Model Number: HTMC150-150, Part Number: DSC1547	Delta Sigma, LLC	8-40 HGz free-space material characterization system for temperatures up to 1,500 °C.	EAR99	12/13/2024
Microcircuit, Pulse Width Modulation (PWM), Current Mode with J-Leads, Model: 561R911 revision E, Part Number: 561R911H03	Corfin Holdings Inc.	A current mode, pulse-width modulation, controller chip with solder coated leads modified to add J-Leads.	Seek a CCATS	12/13/2024
HI-TAK Conductive Gasket with Knitted Aluminum Mesh, Model: Revision A, P/N: PG339000-73	Aviation Devices and Electronic Components LLC	Gasket used to seal and moisture proof between overlapping surfaces, providing environmental protection and electrical conductivity.	EAR99	12/19/2024
1. MAN-PC software, Version 5.0.1.5; 2. MAN-PC Software Activation License; and 3. Silvus StreamCaster radios with MAN-PC software included	Silvus Technologies, Inc.	An activation license and software option for StreamCaster radios.	1, 2: USML Category XI(d) 3: USML Category XI(a)(5)(iii)	12/19/2024
Pressure Gauges, Part Numbers 97200003533 and 97200003534	WIKA Holding, LP	Pressure gauges used in an air-toair refueling system.	Seek a CCATS	12/20/2024
OwlEye	Omitron, Inc	A service for satellites that helps assess and mitigate the risk of collisions with other space objects.	Seek a CCATS	12/20/2024
Neros Valkyrie UAV, Block 1	Neros Technologies	First-person view drone carrying a 3 kg payload.	USML Category VIII(a)(16)	12/20/2024
Image Signals Processing Board	Sheltered Wings, Inc. d/b/a Vortex Optics	Printed circuit board assembly for processing images.	USML Category XII(e)(19)	12/20/2024
SPX-500 and SPX-800, Part Numbers 950058, 950061, 950062, and 950064	Senspex, Inc.	Visible and MWIR Camera Systems	Seek a CCATS	12/29/2024
Services that Include the Loading of Production Parts and Alignment of Production Tooling for Blisks	Manufacturing Technology, Inc.	Assistance in the setup and use of production equipment and tooling for the purpose of producing Blisks	For Blisks described in USML Category XIX(f): USML Category XIX(g) For Blisks not described on the USML: Not a defense service	12/29/2024
FEKO 2019 (Standard), Certain FEKO 2019 Enhancements, and FEKO Enhanced 2019	Altair Engineering, Inc.	Software to evaluate the emissions of electromagnetic energy	Foreign defense articles described in USML Category XIII(i)(4)	12/29/2024
CF-104 Starfighter Display Aircraft, Model F-104, Serial #: 683A-1031	Canadair	Demilitarized and mutilated fighter aircraft with all articles described on the U.S. Munitions List removed and cuts to the airframe to prevent it from being made airworthy.	CCL ECCN 9A610.x	12/30/2024
Performance Requirements, Testing Services, and a Fuel Cell, Version V1.0	Piasecki Aircraft Corporation	High Temperature Proton Exchange Membrane (HTPEM) Hydrogen Fuel Cell for Aviation	Fuel Cell: USML Category XI(a)(7); Services and Information: USML Category XI(d)	12/30/2024
CF-116 Freedom Fighter Display Aircraft, Model CF-5D, Tail Number 116809	Canadair	Demilitarized and mutilated fighter aircraft with all articles described on the U.S. Munitions List removed and cuts to the airframe to prevent it from being made airworthy.	CCL ECCN 9A610.x	12/30/2024
Ballistic Performance Testing and Test Results	Avient Protective Materials LLC	Testing of composite armor panels to the National Institute of Justice (NIJ) Standard 0101.07 RF1 and RF2 levels, including performing the testing and providing test results	USML Category XIII(I)	12/30/2024
WR112 Circulator, Part Number XC3-73	Microwave Techniques, LLC	A circulator used in a radar subsequently used in the Thales Goalkeeper Close-in Weapon System (CIWS).	USML Category VI(f)(7)	12/30/2024
Pistolet-Pulemyot Sudayeva "PPS43" 7.62mm x 25mm Submachine Gun	Minutemen Defense LLC	Fully Automatic Submachine Gun	USML Category I(b)	12/30/2024
Schematic ES-5000 for Cable assembly CX2384	Elbit Systems UK Limited	Schematic depicting a data transfer cable assembly	Seek a CCATS	12/30/2024
EnQuanta Base Suite of products (Vault, Storage, Transfer, and Comms), Model Number: Base V1.0.1	VoiceIt Technologies, Inc. (dba EnQuanta, A VoiceIt Technology Company)	Quantum resilience hybrid cryptographic object code used to provide “incryption” (sic) of digital assets	CCL ECCN 5D002.c.1	12/30/2024
Plain Encased Seal, Part Number 3233429‐2	Quality Industrial Products, Inc.	A component to a thrust reverser actuation system (TRAS) used in the Rolls Royce RB211 turbofan engine	CCL ECCN 9A991.d	12/30/2024
GCA 2000/2020 Radar, Model GCA 2000, (Multiple Part Numbers); MPN-25 Radar, Model MPN-25 BUILD, (Multiple Part Numbers); and AN/MPN-25 Radar, Part Number 276000-1	L3 Harris Technologies, Inc., d. b. a. Space and Airborne Systems	Surveillance radars with Identification Friend or Foe (IFF) and Moving Target Detector (MTD) features	USML Category XI(a)(5)(ii)	12/30/2024
RATTLER UAS, Model Number RATTLER.UAS.V1	Actualized Business Solutions, Inc	Unmanned aerial system (UAS) target drone used to support test and evaluation and training of counter UAS systems	USML Category VIII(a)(10)	1/30/2025
Related to Wire Rope Isolator, Model Number: WR28, Part Number: WR2880004BM	ITT Inc.	Advice regarding installation of the product on a fire control system component	USML Category XII(f)	1/30/2025
Monofilament Vaporization Propulsion (MVP) System	CU Aerospace, LLC	Thruster for small satellites	Seek a CCATS	1/30/2025
Cubesat High Impulse Propulsion System (CHIPS)	CU Aerospace, LLC	Propulsion System for Small Satellites	Seek a CCATS	1/30/2025
Rayon Based Carbon Fabric, CCA-10	Tex-Tech Industries, Inc.	Rayon Based Carbon Fabric	Seek a CCATS	2/9/2025
Periscope Prism Drawing Numbers: 12548771 and 12548772, and Process Specifications: 1247300	Global Photonics, Inc.	Drawings and process specifications for the manufacture of glass prisms for a periscope	USML Category XII(f)	2/9/2025
QuickShot v8.0.2, Part Number QS-XX-XX_CVI4B	SpaceWorks Enterprises, Inc.	Trajectory Optimization Software	EAR99	2/10/2025
Antenna, Part Number S67-1575-714	Sensor Systems, Inc.	M-Code capable antenna	USML Category VIII(f)	2/10/2025
SeaFLIR / TacFLIR 230, SeaFLIR / TacFLIR 240, and SeaFLIR / TacFLIR 280-HD	Teledyne FLIR, LLC	Electro-optical imaging systems with gimbal stabilized 9” turrets	USML Category XII(c)(3)	2/10/2025
Veronte Autopilot, Model 1x, Version 4.8, Part Number P008726	Embention Sistemas Inteligentes SA	User-programable controller for the operation of autonomous devices such as drones, ground vehicles, robots, and surface vehicles	Seek a CCATS	2/10/2025
Automated Portable Raman Microscope (Pendar XM); Pendar XM with Chemical Warfare Agent (CWA) Library; Pendar XM Software; Pendar XM Source Code and Technical Drawings; and Pendar XM Non-CWA Spectral Library	Pendar Technologies LLC	Portable system designed for testing items to detect explosive or drug residues, and, when equipped with the CWA library, certain chemical warfare agents, without contact or damage to the item under test, and related technology	Seek a CCATS	2/10/2025
Spherical Bearing Assembly, Part Number KSC255619B	Kaman Corporation	Component of the tail hook actuator of a fighter aircraft	USML Category VIII(h)(5)	2/13/2025
X-Wall MX+ XN SATA Gen 3 Crypto Module Solution, Part Number X-Wall MX+ xN / x/I with Firmware version 3.8	Enova Technology Corp.	An application-specific integrated circuit (ASIC) engineered for encryption and decryption of standard SATA (Serial Advanced Technology Attachment) storage devices, with a maximum data transfer rate of 6 Gbps	Seek CCATS	2/13/2025
Electric Motor Resolver, Part Number: 433283	Parker-Hannifin Corporation	A rotational position measurement device for use in a hydraulic pump electric motor	USML Category VIII(h)(1)	2/13/2025
Mine Eraser	Ensign-Bickford Aerospace & Defense Company	An energetic line charge containing plastic bonded explosive blocks connected by detonating cord	USML Category IV(c)	2/13/2025
N5193A UXG Firmware and Field Programmable Gate Arrays (FPGAs) (Version A.01.90) and N5194A UXG Firmware and FPGAs (Versions A.02.00 and A.12.00)	Keysight Technologies, Inc.	Firmware and FPGAs for N5193A and N5194A UXG signal generators	UXG Firmware: USML Category XI(d) FPGAs when programmed with FPGA images loaded: USML Category XI(c)(1) Unprogrammed FPGAs: Seek a CCATS Preprogrammed CPLDs: Depends on the export classification of Keysight MXG signal generators	2/13/2025
LED cable assembly, part number P567847	Axon' Cable	Wiring harness with 16 AWG and 24 AWG insulated wire	USML Category VIII(h)(1)	2/13/2025
Diced and Undiced Integrated Circuit Wafers	Skadden, Arps, Slate, Meagher & Flom LLP	Cut and uncut unpackaged integrated circuits programmed for defense articles	USML Category XI(c)(1)	2/13/2025
5 cm x 5 cm Sapphire Substrate and related information	Luxium Solutions, LLC	A transparent, single crystal aluminum oxide substrate that does not exceed the dimensions in USML Category XIII(e)(3) for transparent ceramic plate	EAR99	2/18/2025
Artificial Intelligence Security Platform (AISec Platform) Software, Version 24.10.0	HiddenLayer, Inc.	Security solution to protect AI systems from threats throughout their lifecycle by detecting and responding to risks like malicious inputs and weaknesses in the AI’s underlying components, data sources and development tools	Seek a CCATS	2/18/2025
TrueView R40i Radars, Part Numbers TV-R40iSC, TV- R40iSC+1YSUP, TVR40iSC+SWL+3YS, TV-R40iMC, TV-R40iMC+1YSUP, TVR40iEC+SWL+1YS, TVR40iEC+ SWL+3YS, TV-R40iEC-2.0+1YSUP, and TV-R40iEC, TVR40iMC+ SWL+1YS, TVR40iMC+SWL+3YS	Fortem Technologies, Inc.	Active Electronically Scanned Array (AESA) radars designed for drone detection and airspace security and operating in the KU-Band (15.4-16.6 GHz) with between 16-22 W of power	CCL ECCN 6A008.e	2/18/2025
Power Supply HV/LV, Version Number: REV D, Part Number: 580470	Shigamo Development, Inc. dba: American High Voltage	Power supply for a heads-up display	CCL ECCN 9A610.x	2/18/2025
G‐Loc and GD-Loc Geolocation and Object Positioning Software for Gimbals	Trillium Engineering, LLC	Software tools that provide improved geolocation accuracy and precise object positioning	Seek a CCATS	2/18/2025
GeoDLSR, Version Number: 1.0 and XEN-HUB, Version Number: 1.0	OnOff Block Inc./Xenesis	A space-based network routing software and a Dual Aperture Optical Head Assembly	ECCN 9A515.x/ ECCN 9D515.a	2/18/2025
Soft Telepresence System software, STS Phase 0, Version v.0	Kansas State University	Software that uses augmented reality (AR) to enable a "share what you see" telepresence experience to enhance collaboration by transferring audio and visual input from a remote operator to another person	Seek a CCATS	3/1/2025
S9-Type Laser Diode Array, Model: S9	Leonardo Electronics US, Inc.	Laser diode array that has a thermally conductive base that can incorporate up to 10 high power edge-emitting laser diode bars	USML Category XII(e)(2)	3/1/2025
LEUSI Fiber Amplifier, Model Number: A-40, Part Number: 01-1111	Leonardo Electronics US Inc.	A 2.5 kW continuous wave operation fiber amplifier with narrow linewidth and single output	USML Category XVIII(e)	3/5/2025
Merlin-Handheld-SM and Sidemate, Model 114401-1-4-0, PN 114401-1-4-0	Iris Technology Company	Interfaces between a PRC-163 radio system, a PRC-163 battery, an external power source, and auxiliary equipment to power those items	CCL ECCN 3A611.x	3/10/2025
ARES Lenco BearCat, Model ARES Lenco BearCat 2024	Lenco Industries, Inc.	Off-road capable armored personnel carrier	USML Category VII(e)	3/6/2025
Rechargeable, Nickel Cadmium Battery, model BB-287	ENERSYS	Provides power for the target acquisition and fire control system of a missile system	USML Category XII(e)(1)	3/6/2025
ConductorOS	BigBear.ai, LLC	A software system that enables rapid decision-making and distributed computing by orchestrating data and AI in near real-time, allowing interoperability across diverse environments and easy integration of legacy systems with modern applications	Seek a CCATS	3/6/2025
Project Pantheon	Resilience Government Services, Inc.	Technical information relating to monoclonal antibodies (mAb) or prophylaxis of exposure to aerosolized botulinum neurotoxin A and B serotypes	Not subject to the ITAR or the EAR	3/6/2025
Common Aperture Laser Illuminator Laser Diode Module (LDM) and Common Aperture Laser Pointer LDM	Teledyne Technologies Incorporated	Modules for a laser illuminator and a laser pointer, each used in gimbaled electro-optical surveillance systems	USML Category XII(e)(8)	3/12/2025
High Voltage Power Supply, Model Number: dB-2560	dB Control	A high voltage power supply designed and adapted from the commercial Ka-band and high-power amplifier to work with the Leonardo ET9900 TWT.	USML Category XII(e)(1)	3/12/2025
Uniform Crystals Test Sensors (UCTS) Testing Service and Resulting Test Information	LG Tech-Link Global, LLC	Testing and analysis of material sensors to determine the maximum temperatures the sensors were exposed to	Split based on the application. Defense service and technical data (see definitions) EAR99 when not a defense service or technical data	3/12/2025
M3A1 Pull Wire Fuse Lighter, Model Number: M3A1, Part Number: 1050	Martin & Shaft LLC	Fuse lighter (igniter) for activating ground burst simulators and grenade simulators	Seek a CCATS	3/12/2025
RoadBlock, Vehicle Interdiction Cartridge, MOD 0	Matsys Inc	Shotgun shell containing reactive metals that release thermal energy	USML Category III(a)(3)	3/12/2025
Auxiliary Power Unit (APU) Exhaust, part 461-30001	Senior Operations, LLC	An auxiliary power unit exhaust duct that is designed for an aircraft in development	USML Category VIII(f)	3/12/2025
PowerLight System	PowerLight Technologies	System that uses a laser to transmit power between a transmitter device and receiver device	USML Category XI(a)(7)	3/16/2025
Multi-Shot Robotic EOD Disruptor (MRED) Version 5.1	Vadum, Inc.	Electronically controlled disruptor capable of firing existing 12-gauge disrupter cartridges and water shots	Seek a CCATS	3/16/2025
ARTIV, Model Number: 1.x	DEFCON AI, INC	Modeling, simulation, and analysis simulation software to support mobility and logistics	USML Category IX(b)(4)(iii)	3/16/2025
Aloft X-band Radars, Model: AXR-112-UL-E, SDRT v1; AXR-122-UL-E, SDRT v2; AXR-112-Max-E, SDRT v1; and AXR-122-Max-E, SDRT v2	Thomsen and Burke LLP	Miniature X-band Synthetic Aperture Radars (SAR) used for mid-sized drones, aircraft, and stratospheric vehicles	USML Category XI(a)(3)(ii)	3/16/2025
Mini DDL Transceiver	Aerovironment, Inc.	Communications Transceiver	USML Category XI(a)(5)(i)	3/16/2025
OmniBlast Air, Part Number 01, Model Number OBA; OmniBlast Air+, Part Number 00, Model Number OBA+; OmniBlast Air and OmniBlast Air+ Consulting Services	Advanced Materials and Devices	Wearable blast sensors and associated consulting services	USML Category X(a)(8) until sensors are in production USML Category X(e) for services while sensors are in development USML Category IX(e)(3) for services when not directly related to a defense article	3/16/2025
Schematic of Receiver Integration Fixture (RIF), Part Number TYPII_BREAKOUT_REVB	Navigation Technology Associates, Inc	Schematic showing a device used to test GPS receivers	Seek a CCATS	3/21/2025
RAID Plate Chassis	AeroVironment, Inc.	A chassis, or "spine," that is worn on the back of a UAV operator, holds four modular radios, and provides AI-enhanced common control, open architecture, and advanced networking supporting a complex multi-radio layout.	Seek a CCATS	3/21/2025
Fortem DragonFly, Model DragonFly X100	Fortem Technologies, Inc.	Multi-copter with an onboard radar and customizable user module.	CCL ECCN 6A008.e	3/23/2025
MRAM Radiation hardened memory device	Western Digital Technologies, Inc.	Non-volatile device that stores data in magnetic domains.	Seek a CCATS	3/31/2025
Non-destructive Testing Consulting Services (NDT)	TB3 NDT Consulting LLC	Training and subsequent certifications on NAS-410, SNT-TC 1A, and ANSI/ASNT CP-189 standards.	Seek a CCATS	3/31/2025
Audio Routing Circuit Card with Transit Firmware Installed, Model 6-Channel, Part Number 874-2040-002 (Firmware Version 874-9F01-001)	TTM Technologies, Inc.	Circuit card assembly that performs analog-to-digital and digital-to-analog conversions	USML Category XI(c)(2)	3/31/2025
TAMP Austere, version: 01	GAMS Inc.	Advanced tactical medical training that includes training to return fire to neutralize the enemy while performing initial life-saving interventions, using firearms to establish and maintain a secure cordon around a medical team, and training on the use of certain of defense articles	USML Category IX(e)(3)	3/31/2025
Test Stand, Model 1, Part Number 0001	JINXIN INC	Test Stand	Seek a CCATS	4/7/2025
TF50A Gas Turbine Engine with SPG Power Turbine, Part Number 0-001-010-76; SPG Power Turbine, Model SPG4PT-SN, Part Number SPG4PT-SN-001; Inconel Spacer, Part Number SPG-141-55; Inconel Exhaust Diffuser, Part Number SPG-051-02	Signal Power Group Operating LLC	Marine gas turbine engine with power turbine derived from Honeywell T55-GA-714A kit and two custom components	Engine: CCL ECCN 9A619.a; Power Turbine and Spacer: 9A619.x; Exhaust diffuser: 8A609.x	4/9/2025
Harness, Protected-Side, Left Main A, Model D, Part Number 51586-0101	Collins Aerospace	Wire harness for in-tank fuel quantity indicating system	USML Category VIII(h)(11)	4/14/2025
Photothermal Common-path Interferometer, Model and Part Number PCI-003; and Testing Service	Island Interferometry	A machine that measures thermal absorption in optical materials using a laser, and related services	Interferometer: Seek a CCATS; Testing service: Split; defense service when testing a defense article	4/14/2025
M107 Simulated 155 Artillery Round; M9 Charge bag; and M582 Simulated Fuze	Van Halteren Technologies	Simulated ammunitions that replicate the weight and balance of artillery rounds, charge bags, and fuzes	ECCN 0A614.x	4/14/2025

https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_kb_article_page&sys_id=6ea6afdcdbc36300529d368d7c96194b

*******

DDTC Name And Address Changes Posted To Website

May 2 through May 30, 2025: 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:

Change in Address of Curtiss-Wright Controls Integrated Sensing Inc. from 1150 North Fiesta Boulevard, Gilbert, AZ 85233 to 1100 W Gove Pkwy, Ste. 102, Tempe, AZ 85283;
Change in Address of GTDS America, LLC from 8 Morgan Avenue, Newbury, MA 01951 to 10 Trailside Way, Norfolk, MA 02056;
Change in Name of Airbus GmbH sites in Ausburg and Varel due to corporate restructuring;

From:	To:
Airbus GmbH	Airbus Aerostructures GmbH
Airbus GmbH Plant Ausburg	Airbus Aerostructures GmbH Plant Ausburg
Airbus GmbH Plant Varel	Airbus Aerostructures GmbH Plant Varel

Change in Address of GE Aviation Czech s.r.o from Beranovych 65, 199 02, Letnany, Prague 19902, Czech Republic to Berabovych 65, Praha 9, Praha 199 02, Czech Republic;
Change in Address of a branch of GE Aviation Systems North America LLC from Building Number 7546, Qurtubah District, Unit 1110, Riyadh 13244, Saudia Arabia to Building Number 7546, Qurtubah District, Unit 1110, P.O. Box 2284, Riyadh 13244, Saudi Arabia;
Change in Address of GE India Industrial Pvt. Ltd. from A-18 First Floor, Okhla Industrial Area, Phase II, New Delhi, India 110 020 to Unit 9, First Floor, Hyatt Delhi Residences, Aerocity, New Delhi, India 110 037; and
Change in Address of GE Aviation Systems North America LLC from 21 Leonardo Da Vinci St., Tel Aviv 6473319, Israel to 8 Shaul Hamelech Blvd., Tel Aviv 6473307, Israel.

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DDTC Frequently Asked Questions (FAQs)

Q: I am exporting software source code. Are there any additional requirements I need to be aware of?

A: Yes. Any export of U.S software source code, operating algorithms, signal processing algorithms, and/or program maintenance documentation must be compliant with DoD Guidelines for International Transfers of Software Documentation (including source code), dated 8 April 1997. The request MUST include a full description and explanation of all relevant software modules. Be sure to identify the modules proposed for release, as well as those that will NOT be released. Contact DTSA for a copy of the guidelines or answers to any questions you may have.

Q: Why is a transmittal letter required if information is already stated in application?

A: While the transmittal letter may re-state information already provided in the application, it will allow the applicant to provide further insight into the transaction as well as provide information not specifically required in the license application, i.e., related voluntary disclosure (VD), customs seizure. More importantly, DDTC is moving away from the “stand-alone” license application where no supporting documentation is provided. The inclusion of a transmittal letter re-stating the application information or providing further clarification of the transaction allows for a more robust license file.

Q: My company is entering into an agreement to grant a non-US person authorization to manufacture defense articles abroad. The agreement requires the transfer of ITAR-controlled technical data, defense articles, or the performance of defense services, but we are not transferring manufacturing know-how. Is an MLA still required?

A: Yes. ITAR § 120.57(d) provides that an MLA is an agreement “whereby a U.S. person grants a foreign person an authorization to manufacture defense articles abroad” and involves either (1) exports of defense articles, including technical data, or the performance of a defense service, or (2) the use by the foreign person of technical data or defense articles previously exported by the U.S. person. Thus, an MLA would be appropriate even if no manufacturing know-how is transferred. DDTC may authorize a manufacturing activity under a TAA when it meets all the conditions of ITAR § 124.13 and only limited defense services are furnished (e.g., quality control). Alternatively, if no defense services will be furnished and all the conditions of ITAR § 124.13 are met, an offshore procurement license may be appropriate.

Q: How is a purchase order issued to a subsidiary handled in the license application?

A: The parent company who is the holder of the registration code must be identified in the applicant section of the license application. If the supporting documentation is issued to or identifies a subsidiary of the parent, the subsidiary’s information must be provided in the subsidiary section of the applicant block.

Q: Is an export license required in order to send defense articles to Puerto Rico?

A: No. As ITAR § 120.60 makes clear, Puerto Rico is part of the United States, as are other locations including American Samoa, Guam and the U.S. Virgin Islands. No export occurs when a defense article is shipped to Puerto Rico. Therefore, no export license or other approval from DDTC is required.

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia

May 2, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy one thousand (1,000) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM) and fifty (50) AIM-120C-8 AMRAAM guidance sections. The following non-MDE items will also be included: AMRAAM control section spares, missile containers, and support equipment; spare parts, consumables, accessories, and repair and return support; weapon system support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $3.50 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4173146/kingdom-of-saudi-arabia-aim-120c-8-advanced-medium-range-air-to-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

May 2, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Ukraine requests to buy equipment and services in support of its F-16 aircraft. The following non-MDE items will be included: aircraft modifications and upgrades; personnel training related to operation, maintenance, and sustainment support; spare parts, consumables and accessories, and repair and return support; ground handling equipment; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $310.5 million. The principal contractors will be Valiant Integrated Services, located in Herndon, VA; Top Aces Corporation, located in Mesa, AZ; Lockheed Martin Aeronautics, located in Fort Worth, TX; Pratt and Whitney, located in East Hartford, CT; Snap-on, Inc., located in Kenosha, WI; BAE Systems, Inc., located in Falls Church, VA; AAR Corporation, located in Wood Dale, IL; and Comsetra, LLC, located in Grove, OK. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4173182/ukraine-f-16-training-and-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Norway

May 2, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Norway has requested to buy three hundred (300) AIM-9X Block II Sidewinder tactical missiles; two (2) AIM 9X Block II special air training missiles (NATM); twenty-four (24) AIM 9X Block II captive air training missiles (CATM); twenty (20) AIM 9X Block II Tactical Guidance Units; and twenty (20) AIM 9X Block II CATM Guidance Units. The following non-MDE items will also be included: dummy air training missiles; missile containers; software; training; support equipment; spare and repair parts; publications and technical documentation; transportation; U.S. Government and contractor engineering, technical, and logistical support services; and other related elements of logistics and program support. The estimated total program cost is $370.9 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4173194/norway-aim-9x-block-ii-tactical-missiles

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DSCA Notifies Congress of Potential FMS Sale To the Czech Republic

May 5, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the Czech Republic has requested to buy AN/PYQ-10A(C) simple key loaders; AN/PRC-160, AN/PRC-163, and AN/PRC-167 radios; RF-300M-DL(C) small secure data links and support equipment; spare parts; U.S. Government and contractor technical engineering, logistics, and personnel services; and other related elements of logistics and program support. The estimated total program cost is $181 million. The principal contractor will be L3Harris Global Communications, Inc., located in Rochester, NY. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4174285/czech-republic-communications-equipment

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DSCA Notifies Congress of Potential FMS Sale To the United Arab Emirates

May 12, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the United Arab Emirates (UAE) has requested to buy six (6) CH-47F Block II Chinook helicopters with air-to-air refuel probe capability and extended range fuel tanks; sixteen (16) T-55-GA-714A engines, (12 installed, 4 spares); fourteen (14) Embedded Global Positioning System (GPS)/Inertial Navigation System (INS) (EGI) devices with M-Code (12 installed, 2 spares); eight (8) AN/AAR-57 Common Missile Warning Systems (CMWS) (6 installed, 2 spares); twenty (20) AN/ARC-231A communications security (COMSEC) radios (18 installed, 2 spares); and twenty (20) M-240 machine guns (18 installed, 2 spares). The following non-MDE items will also be included: Common Missile Warning System (CMWS) classified software; AN/APR-39A radar warning receivers; AN/AVR-2B Laser Detecting Sets (LDS); AN/ARC-220 high frequency (HF) radios; KY-100M COMSEC terminals; aircraft survivability equipment (including impulse cartridges for cable cutters and aircraft cartridges); AN/ARN-147 Very High Frequency (VHF) Omni Directional Radio Range/Instrument Landing System (VOR/ILS) receivers; WESCAM MX-15HDi electro-optical/infrared imaging systems; AN/ARN-153 Tactical Airborne Navigation System (TACAN) radios; AN/APN-209 radar altimeters; AN/APX-123A identification friend or foe (IFF) transponders; KIV-77 COMSEC IFF cryptographic appliqués; AN/PYQ-10 Simple Key Loaders; services to support the mission equipment; hardware and services required to implement partner-unique modifications; Fast Rope Insertion/Extraction Systems (FRIES); Internal Extended Range Fuel Systems (ERFS); in-flight refueling capability; firefighting equipment; ballistic armor protection systems; air worthiness support; spare and repair parts; communications equipment; personnel training and training equipment; site surveys; tool and test equipment; ground support equipment; repair and return; publications and technical documentation; Quality Assurance Team (QAT); U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.32 billion. The principal contractors will be Boeing Helicopter Aircraft Company, located in Ridley Park, PA; and Honeywell Engine Company, located in Phoenix, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4182033/united-arab-emirates-ch-47f-chinook-helicopters

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DSCA Notifies Congress of Potential FMS Sale To the United Arab Emirates

May 12, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the United Arab Emirates (UAE) has requested to buy additional F-16 aircraft components, spares, and accessories; and other related elements of logistics and program support that will be added to a previously implemented case whose value was below the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $40.9 million ($0 in MDE), included Common Munitions Built-in-Test Reprogramming Equipment (CMBRE); munitions support equipment; night vision device (NVD) support and spare equipment; spare parts, consumables and accessories; repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; site surveys; studies and surveys; transportation support; U.S. Government and contractor engineering, technical, and logistics support services. The estimated total cost is $130 million. There are no principal contractors associated with this potential sale. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4182037/united-arab-emirates-f-16-sustainment

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DSCA Notifies Congress of Potential FMS Sale To Türkiye

May 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Republic of Türkiye has requested to buy sixty (60) AIM-9X Sidewinder Block II All Up Round (AUR) missiles and eleven (11) AIM-9X Block II Tactical guidance units. The following non-MDE items will be included: missile containers and support equipment; spare parts, and missile support, U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $79.1 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article/4186475/trkiye-aim-9x-sidewinder-block-ii-missiles

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DSCA Notifies Congress of Potential FMS Sale To Türkiye

May 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Republic of Türkiye has requested to buy fifty-three (53) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM); and six (6) AIM-120C-8 AMRAAM guidance sections. The following non-MDE items will be included: AMRAAM containers and support equipment; Common Munitions Built-in-Test (BIT) Reprogramming Equipment (CMBRE); spare parts, consumables and accessories, repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $225 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article/4186456/trkiye-aim-120c-8-advanced-medium-range-air-to-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Bosnia and Herzegovina

May 20, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that Bosnia and Herzegovina has requested to buy AW-119Kx helicopters; qualification and transition training of pilots and maintainers; in-country contractor field service representative support; program management reviews; technical assistance; product support; associated aviation ground support equipment; platform-peculiar ground support equipment; hardware; special tools; test equipment and basic issue items; quality assurance team inspections; inventories; ground run and flight test validation and verification testing; air freight transportation delivery; initial spares, repair and consumable parts; operator maintenance; and technical manuals; 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 $100 million. The principal contractor will be Leonardo Helicopters U.S., AgustaWestland Philadelphia Corporation, located in Philadelphia, PA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article/4192556/bosnia-and-herzegovina-aw-119kx-helicopters

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DSCA Notifies Congress of Potential FMS Sale To Poland

May 21, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy one thousand four hundred (1,400) GBU-39/B Small Diameter Bombs (SDB-I); and four (4) GBU-39 (T-1)/B inert practice bombs with fuzes. The following non-MDE items are also included: GBU-39 tactical training rounds; practice bombs; bomb components; containers; weapons system support; support and test equipment; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical data; personnel training and training equipment; warranties; transportation support; site surveys; U.S. Government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $180 million. The principal contractor will be The Boeing Corporation, located in St. Louis, MO. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article/4194147/poland-gbu-39b-small-diameter-bombs

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DSCA Notifies Congress of Potential FMS Sale To Estonia

May 22, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Estonia has requested to buy eight hundred (800) FGM-148F Javelin missiles (including 8 fly-to-buy missiles) and an additional seventy-two (72) Javelin Lightweight Command Launch Units (LwCLUs) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $10.18 million ($3.1 million in MDE), included twelve (12) LwCLUs; LwCLU Basic Skills Trainers; Javelin missile simulation rounds; Battery Coolant Units; spare parts; tool kits and support equipment; equipment training; U.S. Government and contractor technical assistance and services; engineering services; and related elements of logistics and program support. This notification is for a combined eight hundred (800) FGM-148F Javelin missiles (including 8 fly-to-buy missiles) and eighty-four (84) LwCLUs. The following non-MDE items will also be included: LwCLU Basic Skills Trainers; Javelin missile simulation rounds; Battery Coolant Units; spare parts; tool kits and support equipment; equipment training; U.S. Government and contractor technical assistance and services; engineering services; and related elements of logistics and program support. The estimated total program cost is $296 million. The principal contractors will be the Javelin Joint Venture between RTX Corporation, located in Tucson, AZ, and Lockheed Martin, located in Orlando, FL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article/4195631/estonia-javelin-missiles

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

Department of Commerce Launches Section 232 Steel and Aluminum Inclusions Process

May 1, 2025: On April 30, 2025, the Department of Commerce issued an interim final rule establishing a new tariff inclusion process for derivative aluminum and steel articles.

This action follows the issuance of Presidential Proclamations 10895 and 10896, collectively known as the “Inclusion Proclamations,” which direct the Secretary of Commerce to establish a mechanism for expanding the scope of steel and aluminum tariffs to cover “derivative” articles that contain steel or aluminum.
The Section 232 inclusions process allows U.S. manufacturers and trade associations to request the inclusion of new derivative articles under Section 232 steel and aluminum tariffs. Inclusions may be submitted during any of three defined periods each year. The first submission period opens May 1, 2025. The public will have an opportunity to comment on inclusion requests, and decisions will be issued within 60 days. BIS will publicly post its determinations on Regulations.gov.
Today’s rule also eliminates the Section 232 aluminum and steel exclusions process. In accordance with the Inclusion Proclamations, no new applications for product exclusions have been accepted after February 10,2025.
Jeffrey Kessler, Under Secretary of Commerce for Industry and Security, said:
“The new steel and aluminum inclusions process will extend the reach of the steel and aluminum tariff program and shut down avenues for circumvention – bringing industry and jobs back to the United States.”
Beyond the establishment of the steel and aluminum inclusions process, Commerce is currently conducting six Section 232 investigations in support of the President’s America First Agenda, including inquiries into the national security impact of imports of copper, timber, lumber, semiconductors, pharmaceuticals, critical minerals, and medium- and heavy-duty trucks into the United States. In addition, Commerce recently imposed tariffs on autos and auto parts under Section 232.

https://media.bis.gov/press-release/department-commerce-launches-section-232-steel-aluminum-inclusions-process

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Department of Commerce Rescinds Biden-Era Artificial Intelligence Diffusion Rule, Strengthens Chip-Related Export Controls

May 13, 2025: The Department of Commerce initiated a rescission of the Biden Administration’s AI Diffusion Rule, while announcing additional steps to strengthen export controls on semiconductors worldwide.

The AI Diffusion Rule was issued on January 15, 2025, with compliance requirements that were set to come into effect on May 15, 2025. These new requirements would have stifled American innovation and saddled companies with burdensome new regulatory requirements. The AI Diffusion Rule also would have undermined U.S. diplomatic relations with dozens of countries by downgrading them to second-tier status.

BIS plans to publish a Federal Register notice formalizing the rescission and will issue a replacement rule in the future.

Under Secretary of Commerce for Industry and Security Jeffery Kessler has instructed BIS enforcement officials not to enforce the Biden Administration’s AI Diffusion Rule, stating:

“The Trump Administration will pursue a bold, inclusive strategy to American AI technology with trusted foreign countries around the world, while keeping the technology out of the hands of our adversaries. At the same time, we reject the Biden Administration’s attempt to impose its own ill-conceived and counterproductive AI policies on the American people.”

In addition, BIS announced actions to strengthen export controls for overseas AI chips, including:

Issuing guidance alerting industry to the risks of using PRC advanced computing ICs, including specific Huawei Ascend chips.
Issuing guidance warning the public about the potential consequences of allowing U.S. AI chips to be used for training and inference of Chinese AI models.
Issuing guidance to U.S. companies on how to protect supply chains against diversion tactics.

These actions ensure that the United States will remain at the forefront of AI innovation and maintain global AI dominance.

https://media.bis.gov/press-release/department-commerce-rescinds-biden-era-artificial-intelligence-diffusion-rule-strengthens-chip-related

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Reporting for Calendar Year 2024 on Offsets Agreements Related to Sales of Defense Articles or Defense Services to Foreign Countries or Foreign Firms

May 21, 2025: 90. Fed. Reg. 21738: This notice is to remind the public that U.S. firms are required to report annually to the Department of Commerce (Commerce) information on contracts for the sale of defense articles or defense services to foreign countries or foreign firms that are subject to offsets agreements exceeding $5,000,000 in value. U.S. firms are also required to report annually to Commerce information on offsets transactions completed in performance of existing offsets commitments for which an offsets credit of $250,000 or more has been claimed from the foreign representative. This year, such reports must include relevant information from calendar year 2024 and must be submitted to Commerce no later than June 15, 2025.

https://www.federalregister.gov/documents/2025/05/21/2025-09139/reporting-for-calendar-year-2024-on-offsets-agreements-related-to-sales-of-defense-articles-or

U.S. Census Bureau

Update to Automated Export System (AES) Appendix F – Update to C65 and C75 License Type Codes

May 6, 2025:

CSMS # 64956194 - Update to Automated Export System (AES) Appendix F – Update to C65 and C75 License Type Codes

Update to the Automated Export System Trade Interface Requirements – Appendix F has been posted to CBP.gov.

The following license type codes have been updated:

License Code: C65

Removed 3A991 ECCN
Added 3B991 ECCN

License Code: C75

Added 5A002.z

Documentation is available under the ACE AESTIR Appendix F - License and License Exemption Type Codes webpage which can be located at: https://www.cbp.gov/document/guidance/aestir-appendix-f-license-and-license-exemption-type-codes

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Update to AESDirect – Displaying Participating Government Agency (PGA) Records

May 15, 2025:

Note: This update is specific to filers who use AESDirect as their connection method.

AESDirect will be updated on Tuesday, May 20, 2025, to allow all AESDirect participants to see the PGA requirements that have been integrated in AESDirect. Prior to this change, some PGA requirements were based on Pilot participation and were only available to those participants.

When a Schedule B/ HTS number is found on Appendix X, the appropriate PGA record will now be available to all filers in AESDirect based on each agency’s requirements. Shipments subject to PGA data requirements must submit a PGA record in the Automated Export System (AES).

When reporting for PGA data, filers will need to indicate ‘Yes’ in Step 3 to the question: Does this filing require Participating Government agency data? The additional PGA data will then display for you to enter the appropriate data elements.

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How to Resolve Common AES Response Messages

May 19, 2025

Note: This message is sent to all AES Updates subscribers and is for educational purposes only.

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: 136

Narrative: PR to US Requires PR Port of Export

Severity: Fatal

Reason: The Country of Destination is reported as the Unites States and the Port of Export Code is not a Puerto Rican port.

Resolution: A Port of Export Code must be reported on shipments from Puerto Rico to the United States and it must be a Puerto Rican port.

See Appendix D, Export Port Codes for a list of acceptable Port of Export Codes.

Verify the Country of Ultimate Destination and Port of Export Code, correct the shipment and resubmit.

For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.

As a reminder, filers have multiple resources that they can use when filing EEI to the AES. You can access User Guides, Walk-through videos and other resources at our website.

LATEST SANCTIONS FINES & PENALTIES

Fines and Penalties

May 22, 2025: 90 Fed. Reg. 21886: On April 17, 2024, in the U.S. District Court for the Middle District of Florida, Sergey Karpushkin (“Karpushkin”), was convicted of violating 18 U.S.C. 371. Specifically, Karpushkin conspired with others to purchase and receive over $139 million in metal products from companies owned by a sanctioned oligarch. As a result of his conviction, the Court sentenced Karpushkin to 21 months of imprisonment, with credit for time served, and three years of supervised release.

Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 371, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.

BIS received notice of Karpushkin's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Karpushkin to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Karpushkin.

Based upon the Office of Export Enforcement’s review of the record and consultations with BIS' Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Karpushkin's export privileges under the Regulations for a period of 10 years from the date of Karpushkin's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Karpushkin had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/05/22/2025-09174/in-the-matter-of-sergey-karpushkin-3740-ne-207th-terrace-miami-fl-33180-order-denying-export

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May 22, 2025: 90 Fed. Reg. 21887: On March 1, 2023, in the U.S. District Court for the District of Arizona, Arlando Torres (“Torres”) was convicted of violating 18 U.S.C. 554(a). Specifically, Torres was convicted of smuggling and attempting to smuggle from the United States to Mexico, 1,680 rounds of 5.56mm ammunition, 1,000 rounds of 10mm ammunition, 3,200 rounds of 7.62x39mm ammunition, and 50 rounds of 7.62x25mm ammunition. As a result of his conviction, the Court sentenced Torres to 41 months of imprisonment with credit for time served, and three years of supervised release.

Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 554, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.

BIS received notice of Torres's conviction for violating 18 U.S.C. 554. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Torres to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Torres.

Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, the have decided to deny Torres's export privileges under the Regulations for a period of 10 years from the date of Torres's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Torres had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/05/22/2025-09170/order-denying-export-privileges-arlando-torres-304-7th-street-hico-tx-76457

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May 22, 2025: 90 Fed. Reg. 21889; On May 19, 2023, in the U.S. District Court for the Southern District of Florida, Osmani Valdivia Perez (“Perez”), was convicted of violating 18 U.S.C. 371. Specifically, Perez pled guilty to conspiring with others to export from the United States to Mexico stolen vessel parts, specifically outboard engines. As a result of his conviction, the Court sentenced Perez to 60 months in prison and three years of supervised release.

BIS received notice of Perez's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Perez to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Perez.

Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Perez's export privileges under the Regulations for a period of seven (7) years from the date of Perez's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Perez had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/05/22/2025-09172/in-the-matter-of-osmani-valdivia-perez-inmate-number-33469-018-fci-coleman-low-federal-correctional

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May 22, 2025: 90 Fed. Reg. 21890: On December 19, 2023, in the U.S. District Court for the Western District of Texas, Steve Trevino (“Trevino”) was convicted of violating 18 U.S.C. 554(a) (Smuggling Goods from the United States). Specifically, Trevino was convicted of smuggling firearms from the United States to Mexico. As a result of his conviction, the Court sentenced Trevino to 57 months of imprisonment and three years of supervised release.

Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 554, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.

BIS received notice of Trevino's conviction for violating 18 U.S.C. 554. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Trevino to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Trevino.

Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Trevino's export privileges under the Regulations for a period of 10 years from the date of Trevino's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Trevino had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/05/22/2025-09175/in-the-matter-of-steve-trevino-7014-palacios-cv-san-antonio-tx-78242-2327-order-denying-export

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May 22, 2025: 90 Fed. Reg. 2188: On May 19, 2023, in the U.S. District Court for the Southern District of Florida, Roberto Marrero-Cisneros (“Marrero-Cisneros”) was convicted of violating 18 U.S.C. 371 (conspiracy to export stolen vessel parts and to smuggle goods from the United States). Specifically, Marrero-Cisneros conspired with others to export from the United States to Mexico boat engines and parts that were stolen, in violation of 18 U.S.C. 553(a)(1), and to export boat engines and parts contrary to law, in violation of 18 U.S.C. 554(a). As a result of his conviction, the Court sentenced Marrero-Cisneros to 60 months of imprisonment and three years of supervised release.

BIS received notice of Marrero-Cisneros's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Marrero-Cisneros to make a written submission to BIS. 15 CFR 766.25.^[²^]BIS has not received a written submission from Marrero-Cisneros.

Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Marrero-Cisneros's export privileges under the Regulations for a period of seven (7) years from the date of Marrero-Cisneros's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Marrero-Cisneros had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/05/22/2025-09173/in-the-matter-of-roberto-marrero-cisneros-inmate-number-24458-018-fci-jesup-federal-correctional

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May 22, 2025: 90 Fed. Reg. 21887: On May 23, 2023, in the U.S. District Court for the Southern District of Florida, Carlos Orlando Ledesma (“Ledesma”), was convicted of violating 18 U.S.C. 371 (conspiracy to export stolen vessel parts and to smuggle goods from the United States). Specifically, Ledesma conspired with others to export from the United States to Mexico boat engines and parts that were stolen, in violation of 18 U.S.C. 553(a)(1), and to export boat engines and parts contrary to law, in violation of 18 U.S.C. 554(a). As a result of his conviction, the Court sentenced Ledesma to 36 months of imprisonment and three years of supervised release.

BIS received notice of Ledesma's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Ledesma to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Ledesma.

Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Ledesma's export privileges under the Regulations for a period of seven (7) years from the date of Ledesma's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Ledesma had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/05/22/2025-09171/in-the-matter-of-carlos-orlando-ledesma-980-nw-127th-ave-miami-fl-33182-order-denying-export

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Sanctions

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

May 1, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three Mexican nationals, and two Mexico-based entities involved in a drug trafficking and fuel theft network linked to the Cartel Jalisco Nueva Generacion (CJNG). This network generates hundreds of millions of dollars annually, benefitting CJNG, through a slew of criminal activities, including fentanyl trafficking, fuel theft, and smuggling stolen crude oil from Mexico across the southwest border. Concurrently, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert that provides financial typologies and red flags indicative of crude oil smuggling schemes on the U.S. southwest border associated with CJNG and other Mexico-based transnational criminal organizations.

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

Morfin Morfin, Alvao Noe of Mexico;
Morfin Morfin, Cesar of Mexico; and
Morfin Morfin, Remigio of Mexico.

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

Grupo Jala Logistica, S.A. DE C.V. of Mexico; and
Servicios Logisticos Ambientales, S.A. DE C.V. of Mexico.

https://ofac.treasury.gov/recent-actions/20250501 and

https://ofac.treasury.gov/media/934256/download?inline=

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May 2, 2025: The United States remains committed to protecting our national security interests and dismantling violent criminal gangs terrorizing the Haitian people.

The Department of State announced the designation of Viv Ansanm and Gran Grif as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs).

Viv Ansanm is a group formed in September 2023 as a coalition of gangs through an alliance between the two main gang factions operating in Port-au-Prince, G-9 and G-Pép.
The groups provide a unified platform for criminal groups to use violence to destabilize Haiti and quash actions aimed at restoring state control. Viv Ansanm has launched coordinated attacks on critical infrastructure in Haiti, including prisons, government buildings, and Haiti’s main airport in Port-au-Prince as part of a campaign that, among other things, forced the resignation of former Haitian Prime Minister Ariel Henry.
Gran Grif is the largest gang in Haiti’s Artibonite department, a region that is home to much of the country’s rice fields. Since 2022, Gran Grif has been responsible for 80 percent of civilian death reports in Artibonite. Gran Grif has attacked Haitian National Police and the UN-authorized Multinational Security Support (MSS) mission, including in the February 2025 attack that killed a Kenyan MSS mission officer.

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

Gran Grif of Haiti; and
Viv Ansanm of Haiti.

https://ofac.treasury.gov/recent-actions/20250502 and

https://www.state.gov/designation-of-viv-ansanm-and-gran-grif/

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May 5, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Karen National Army (KNA), a militia group in Burma, as a transnational criminal organization, along with the group’s leader Saw Chit Thu, and his two sons, Saw Htoo Eh Moo and Saw Chit Chit, for their role in facilitating cyber scams that harm U.S. citizens, human trafficking, and cross-border smuggling. The KNA-controlled region, located on the Thai-Burmese border, is home to multiple cyber scam syndicates, and the KNA has benefitted from its connection to Burma’s military in its criminal operations. Although statistics vary, American victims of cyber scams like the ones emanating from Burma have collectively lost billions of dollars over the last three years.

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

Chit, Saw Chit of Burma;
Eh Moo, Saw Htoo of Burma; and
Thu, Saw Chit of Burma.

The following entity has been added to OFAC’s SDN List:

Karen National Army of Burma.

https://ofac.treasury.gov/recent-actions/20250505 and

https://home.treasury.gov/news/press-releases/sb0129

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May 8, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) increased pressure on Iran’s export of oil, designating the “teapot” refinery Hebei Xinhai Chemical Group Co., Ltd. and three port terminal operators in Shandong Province for their role in purchasing or facilitating the delivery of hundreds of millions of dollars’ worth of Iranian oil. These teapot refineries, most of which are located in Shandong Province, purchase the majority of Iranian crude oil exports. OFAC also imposed sanctions on several companies, vessels, and captains responsible for facilitating Iranian oil shipments as part of Iran’s “shadow fleet.” This is OFAC’s third action against a teapot refinery and its first targeting terminal operators in Shandong Province.

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

Agarwal, Ketan of India; and
Viegas, Lincoln Francisco of India.

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

Baogang Dongying Donggang Logistics and Warehousing Co., Ltd. of China;
Embrace Que Limited of China;
Hebei Xinhai Chemical Group Co., Ltd. of China;
Hong Kong Prime Trading Co., Limited of China;
Nissho Lines Incorporated of the Marshall Islands;
Propitous Forever Trading Co Ltd of the United Kingdom;
Shandong Baogang International Port Co., Ltd. of China;
Shandong Jingang Port Co., Ltd. of China;
Skadi Limited of the Marshall Islands;
Star Twinkle Shipping Limited of China; and
Xing AO Energy Pte. Ltd. of Singapore.

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

Big Mag (HORS) Crude Oil Tanker Panama flag; MMSI 356336000 (vessel);
Impalas (S9Z4) Crude Oil Tanker Sao Tome & Principe flag; MMSI 668116257 (vessel);
Lamd (a.k.a. TAI HE) (3E6106) Crude Oil Tanker Panama flag; MMSI 352003859 (vessel);
Skadi (HPPN) Crude Oil Tanker Panama flag; MMSI 352421000 (vessel);
Star Twinkle 6 (3E5173) Crude Oil Tanker Panama flag; MMSI 352003519 (vessel); and
Thane (T7BR8) Crude Oil Tanker San Marino flag; MMSI 268246702 (vessel).

https://ofac.treasury.gov/recent-actions/20250508

https://home.treasury.gov/news/press-releases/sb0135

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May 12, 2025: Sayyed Mohammad Reza Seddighi Saber is the head of Iran’s Organization of Defensive Innovation and Research’s (also known by its Persian acronym, SPND) Shahid Karimi Group, a group that works on explosives-related projects. Seddighi Saber is linked to projects including research and testing applicable to the development of nuclear explosive devices.

Ahmad Haghighat Talab is an SPND senior official and a nuclear scientist who was previously involved in Iran’s pre-2004 weapons program: the Amad Project. Talab continues to use his scientific expertise to advance Iran’s nuclear-related research and development efforts that have potential military applications. As an SPND senior official, Talab also coordinates with Iranian researchers who work on nuclear research with dual-use purposes.

Mohammed Reza Mehdipur is a longtime SPND-affiliated official who has been involved in explosion and shock research on behalf of SPND. Mehdipur was appointed as head of SPND’s Shahid Chamran Group, which has conducted nuclear-related research. As a longtime explosives and nuclear researcher, Mehdipur has supported SPND’s nuclear and explosives research and development efforts, including those with potential military applications.

Fuya Pars Prospective Technologists, also known as Ideal Vacuum, is an SPND-affiliated company that has attempted to procure from foreign suppliers, as well as indigenously fabricate, equipment that could be applicable in nuclear weapons research and development.

The Department of State is designating Fuya Pars Prospective Technologists (Ideal Vacuum), Sayyed Mohammad Reza Seddighi Saber, Ahmad Haghighat Talab, and Mohammed Reza Mehdipur for sanctions pursuant to E.O. 13382 for engaging or attempting to engage in activities or transactions that materially contribute to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery (including missiles capable of delivering such weapons), including any efforts to manufacture, acquire, possess, develop, transport or transfer such items, by Iran, a foreign country of proliferation concern.

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

Saber, Sayyed Mohammed Reza Seddighi of Iran; and
Talab, Ahmad Haghighat of Iran.

The following entity has been added to OFAC’s SDN List:

Fuya Pars Prospective Technologists of Iran.

https://ofac.treasury.gov/recent-actions/20250512

https://www.state.gov/releases/office-of-the-spokesperson/2025/05/imposition-of-new-u-s-sanctions-related-to-iranian-nuclear-related-research-with-potential-military-applications/

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May 13, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nearly two dozen firms operating in multiple jurisdictions in virtually every aspect of Iran’s illicit international oil trade. The Iranian government allocates billions of dollars’ worth of oil annually to its armed forces to supplement their budget allocations, underwriting the development of ballistic missiles and unmanned aerial vehicles, as well as financing regional terrorist groups. Iran’s Armed Forces General Staff (AFGS) and its main commercial affiliate, Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), continue to establish front companies and rely on buyers and facilitators to enable their sanctioned oil trade. Since the start of this administration, Treasury has rapidly moved to implement President Trump’s maximum pressure campaign on Iran and have taken 19 actions, sanctioning 253 individuals, entities, and vessels related to Tehran and its proxies.

The following individual has been added to OFAC’s SDN List:

Khorasani Niasari, Mohammad of Iran.

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

CCIC Singapore Pte. Ltd. of Singapore;
Continental Sinoil Group Limited of China;
Fine Sanmata Shipping Co., Limited of China;
Forsal Chartering Corporation of Seychelles;
Huangdao Inspection and Certification Co., Ltd of China;
Metaone Trading Limited of China;
Milen Trading Co., Limited of China;
Nanhai Limited of China;
Oriental Apple Company Pte Ltd of Singapore;
Qingdao Fushen Petrochemical Co., Ltd of China;
Qingdao Linkrich International Shipping Agency Co., Ltd of China;
South Sea Energy Limited of China;
Star Energy International Limited of China;
Winso Trading Limited of China; and
Xin Rui Ji Trad Co., Limited of China.

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

Balu (TJM0133) Floating Storage Tanker Cameroon flag; MMSI 613469620 (vessel); and
Roc (3E6750) Crude Oil Tanker Panama flag; MMSI 352004455 (vessel).

https://ofac.treasury.gov/recent-actions/20250513

https://home.treasury.gov/news/press-releases/sb0139

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May 14, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and 12 entities for their involvement in efforts to help the Iranian regime domestically source the manufacturing of critical materials needed for Tehran’s ballistic missile program. Those sanctioned support the various Islamic Revolutionary Guard Corps (IRGC) sub-organizations that oversee the effort to help Iran domestically develop carbon fiber materials needed to manufacture intercontinental ballistic missiles. This action is being taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied intercontinental ballistic missiles and that the IRGC and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities.

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

Qin, Dehui of China;
Qin, Jinhua of China;
Rezai, Mohammad of Iran;
Wang, Chao of China; and
Wang, Piao of China.

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

Advanced Fiber Development Company of Iran;
Nantong Tanchen High Performance Material Co Ltd of China;
Nantong Yihong New Materials Co Ltd of China;
Qingdao Premier Technology Co Ltd of China;
Reso Trading Shanghai Co Ltd of China;
Sarmand Sazeh Sazan Saroush of Iran;
Shanghai Ninestex New Material Technology Co Ltd of China;
Shanghai Tanchain New Material Technology Co Ltd of China;
Sharif Hamrah Science and Technology Researchers of Iran; and
Super Sources Industrial Co Limited.

https://home.treasury.gov/news/press-releases/sb0142

https://ofac.treasury.gov/recent-actions/20250514

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May 15, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted two senior Hizballah officials and two financial facilitators for their roles in coordinating financial transfers for Hizballah. These individuals, based in Lebanon and Iran, work closely with Hizballah leadership to send money to the group from overseas donors. These donations are a significant portion of the terrorist group’s overall budget. In addition to managing and processing funding for Hizballah within Lebanon, one of these individuals is responsible for overseeing financial activity for Hizballah-aligned groups around the world.

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

Alami, Jihad of Lebanon;
Al-‘Amili, Mu’in Daqiq of Lebanon;
Nehme, Fadi of Lebanon; and
Ni’Mah, Hasan Abdallah of Lebanon.

https://ofac.treasury.gov/recent-actions/20250515

https://home.treasury.gov/news/press-releases/sb0143

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May 15, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related General License 124, "Authorizing Petroleum Services Related to the Caspian Pipeline Consortium and Tengizchevroil."

GENERAL LICENSE NO. 124: “Authorizing Petroleum Services Related to the Caspian Pipeline Consortium and Tengizchevroil Projects”

All transactions prohibited by the determination of January 10, 2025 made pursuant to section 1(a)(ii) of Executive Order 14071 (“Prohibition on Petroleum Services”) that are related to the Caspian Pipeline Consortium or Tengizchevroil projects are authorized.

Additionally, OFAC has published an updated Russia-related Frequently Asked Question (FAQ 1216).

FAQ 1216:

Q: What action has Treasury taken with regard to the provision of petroleum services to Russia?

A: In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services ("the Petroleum Services Determination"). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination took effect at 12:01 a.m. eastern standard time on February 27, 2025. See FAQ 1217 for additional information.

OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia's ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia's domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.

OFAC issued General License 121 to authorize any petroleum services that would otherwise be prohibited by the Petroleum Services Determination related to the operations of the Caspian Pipeline Consortium (CPC), Tengizchevroil, and Sakhalin II. GL 121 expires on June 28, 2025. On May 15, 2025, OFAC issued GL 124, which extends without time limitation authorizations related to the CPC and Tengizchevroil.

The Petroleum Services Determination does not apply to (1) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (2) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (3) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.

https://ofac.treasury.gov/media/934251/download?inline

https://ofac.treasury.gov/faqs/1216

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May 20, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Iran-related General License Q, "Authorizing Limited Safety, Environmental, and Sale Transactions Involving the Blocked Vessel M.V. Tinos I While Located in the United States."

GENERAL LICENSE Q: “Authorizing Limited Safety, Environmental, and Sale Transactions Involving the Blocked Vessel M.V. Tinos I While Located in the United States”

(a) All transactions prohibited by Executive Order (E.O.) 13902 involving the vessel M.V. Tinos I (IMO: 9969821) (Tinos I), Meisam Emamjomeh, or Pearl Petrochemical FZE, or any entity in which any of the foregoing owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are ordinarily incident and necessary to one or more of the following activities are authorized, provided that any payments to a blocked person must be made into a blocked interest-bearing account at a U.S. financial institution:

(1) The safe docking and anchoring of the Tinos I in port;

(2) The preservation of the health and safety of the crew of the Tinos I;

(3) Emergency repairs and environmental mitigation or protection activities related to the Tinos I;

(4) The provision of vessel management, bunkering, pilotage, towing, insurance, classification, flagging, registration, crewing, or port agency services for the Tinos I, as well as other services necessary to maintain normal vessel standards for the Tinos I; or

(5) The sale of the Tinos I provided the net proceeds of the sale be placed into a blocked interest-bearing account at a U.S. financial institution.

Note to paragraph (a)(5). Transactions authorized by paragraph (a)(5) include: bidding on the purchase of the vessel; paying deposits; providing financing, insurance, or funding in connection with the purchase; and, in furtherance of the sale of the vessel, repairing or modifying the vessel for commercial use and hiring surveyors to inspect the vessel.

https://ofac.treasury.gov/media/934291/download?inline

https://ofac.treasury.gov/recent-actions/20250520

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May 21, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two high-ranking members of the Mexico-based Cartel del Noreste (CDN), formerly known as Los Zetas. CDN, one of the most violent drug trafficking organizations in Mexico and a U.S.-designated Foreign Terrorist Organization (FTO), exerts significant influence over the border region, especially near the Laredo/Nuevo Laredo point of entry. These sanctions underscore the commitment to target CDN and other violent cartels involved in drug trafficking, human trafficking, arms trafficking, and other heinous crimes that are endangering the American people.

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

De Anda Ledezma, Miguel Angel of Mexico; and
Gonzalez Sauceda, Ricardo of Mexico.

https://ofac.treasury.gov/recent-actions/20250521

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May 23, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with the President’s announcement for the cessation of all sanctions on Syria. GL 25 authorizes transactions prohibited by the Syrian Sanctions Regulations, effectively lifting sanctions on Syria. GL 25 will enable new investment and private sector activity consistent with the President’s America First strategy. The U.S. Department of State concurrently issued a waiver under the Caesar Syria Civilian Protection Act (Caesar Act) that will enable our foreign partners, allies, and the region to further unlock Syria’s potential. This is just one part of a broader U.S. government effort to remove the full architecture of sanctions imposed on Syria due to the abuses of the Bashar al-Assad regime.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Syria General License 25, "Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons."

GENERAL LICENSE NO. 25: “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons”

(a) All transactions prohibited by the Syrian Sanctions Regulations, 31 CFR part 542 (SySR), other than transactions involving blocked persons, are authorized.

(b) All transactions that are prohibited by the SySR, the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 CFR part 544, the Iranian Financial Sanctions Regulations, 31 CFR part 561, the Global Terrorism Sanctions Regulations, 31 CFR part 594, the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597, or Executive Order 13574 involving the following blocked persons are authorized:

(1) the Government of Syria, as defined by 31 CFR § 542.308, as in existence on or after May 13, 2025; (2) any blocked person listed in the Annex to this general license; or

(3) any entity in which one or more of the blocked persons listed in the Annex own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

Note to paragraph (b)(1). The Government of Syria includes Syrian President Ahmed al-Sharaa and his government.

https://ofac.treasury.gov/recent-actions/20250523_33

https://home.treasury.gov/news/press-releases/sb0148

https://ofac.treasury.gov/media/934306/download?inline

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May 29, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Funnull Technology Inc., a Philippines-based company that provides computer infrastructure for hundreds of thousands of websites involved in virtual currency investment scams, commonly known as “pig butchering,” along with its administrator, Liu Lizhi. Americans lose billions of dollars annually to these cyber scams, with revenues generated from these crimes rising to record levels in 2024. Funnull has directly facilitated several of these schemes, resulting in over $200 million in U.S. victim-reported losses.

The following individual has been added to OFAC’s SDN List:

Liu, Lizhi of China.

The following entity has been added to OFAC’s SDN List:

Funnull Technology Inc of China.

https://home.treasury.gov/news/press-releases/sb0149

https://ofac.treasury.gov/recent-actions/20250529

MAY 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

APRIL 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through April 30, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

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

REGULATORY UPDATES

President

The President Announces Executive Order to Reform Foreign Defense Sales To Improve Speed and Accountability

April 9, 2025: To serve the interests of the American people, the United States must maintain the world’s strongest and most technologically advanced military through a dynamic defense industrial base, coupled with a robust network of capable partners and allies. A rapid and transparent foreign defense sales system that enables effective defense cooperation between the United States and our chosen partners is foundational to these objectives. Reforming this system would simultaneously strengthen the security capabilities of our allies and invigorate our own defense industrial base. This mutually reinforcing approach would enhance United States warfighting capabilities by fostering healthy American supply chains, domestic production levels, and technological development.

Sec. 2. Policy. It is the policy of the President’s Administration to:

(a) Improve accountability and transparency throughout the foreign defense sales system to ensure predictable and reliable delivery of American products to foreign partners in support of United States foreign policy objectives.

(b) Consolidate parallel decision-making when determining which military capabilities the United States will choose to provide, and to which countries.

(c) Reduce rules and regulations involved in the development, execution, and monitoring of foreign defense sales and of transfer cases to ensure alignment with United States foreign policy objectives.

(d) Increase government-industry collaboration to achieve cost and schedule efficiencies in the execution of the Foreign Military Sales (FMS) program.

(e) Advance United States competitiveness abroad, revitalize the defense industrial base, and lower unit costs for the United States and our allies and partners by integrating exportability features in the design phase, improving financing options for partners, and increasing contract flexibility overall.

Sec. 3. Phased Implementation.

(a) The Secretary of State and the Secretary of Defense shall promptly:

(i) Implement National Security Presidential Memorandum 10 of April 19, 2018 (United States Conventional Arms Transfer Policy), or any successor policy directive.

(ii) Reevaluate restrictions imposed by the Missile Technology Control Regime on Category I items and consider supplying certain partners with specific Category I items, in consultation with the Secretary of Commerce.

(iii) Submit a joint letter to the Congress proposing an update to statutory congressional certification (also known as congressional notification) thresholds of proposed sales under the FMS and Direct Commercial Sales (DCS) programs in the Arms Export Control Act (22 U.S.C. 2751 et seq.). The Secretary of State shall also work with the Congress to review congressional notification processes to ensure the timely adjudication of notified FMS and DCS cases.

(b) Within 60 days of the date of this order:

(i) The Secretary of State, in consultation with the Secretary of Defense, shall develop a list of priority partners for conventional arms transfers and issue updated guidance to Chiefs of the United States Diplomatic Missions regarding this list.

(ii) The Secretary of Defense, in consultation with the Secretary of State, shall:

(A) develop a list of priority end-items for potential transfer to priority partners identified by the Secretary of State in the list required by this subsection;

(B) ensure the transfer of priority end-items to priority partners would not cause significant harm to United States force readiness; and

(C) ensure the transfer of priority end-items to priority partners would advance my Administration’s goal of strengthening allied burden-sharing, both by sharing the cost of end-item production and by increasing our allies’ capacity to meet capability targets independently, without sustained support from the United States.

(c)(i) The Secretary of State and the Secretary of Defense shall review, update, and reissue the lists of priority partners and military end-items on an annual basis. The United States Munitions List, 22 C.F.R. part 121, to focus protections solely on our most sensitive and sophisticated technologies and shall establish clear criteria for including an item on the FMS-Only List.

(c)(ii) The Secretary of State and the Secretary of Defense shall review and update the list of defense items that can only be purchased through the FMS process (the FMS-Only List) and the United States Munitions List, 22 C.F.R. part 121, to focus protections solely on our most sensitive and sophisticated technologies, and shall establish clear criteria for including an item on the FMS-Only List.

(d) Within 90 days of the date of this order, the Secretary of State and the Secretary of Defense, in consultation with the Secretary of Commerce, shall submit a plan to the President, through the Assistant to the President for National Security Affairs (APNSA), to: improve the transparency of United States defense sales to foreign partners by developing metrics for accountability; secure exportability as a requirement in the early stages of the acquisition process; and consolidate technology security and foreign disclosure approvals.

(e) Within 120 days of the date of this order, the Secretary of Defense, with the assistance of the Secretary of State and the Secretary of Commerce, shall submit a plan to the APNSA to develop a single electronic system to track all DCS export license requests and ongoing FMS efforts throughout the case life-cycle.

Sec. 4. Definitions. For purposes of this order:

(a) “Parallel decision-making” refers to the granting of simultaneous certifications and approvals during the FMS process, as opposed to sequential decision-making where agencies wait for other agencies to make decisions before taking action.

(b) “Exportability” means the process to identify, develop, and integrate technology protection features into United States defense systems early in the acquisition process to protect critical technologies, capabilities, and program information and thus enable export to partners.

(c) “FMS-only” means defense articles that are exclusively available through the FMS process as opposed to the DCS process, as authorized in the Arms Export Control Act and described in the Security Assistance Management Manual (SAMM), Defense Security Cooperation Agency (DSCA), Chapter 4.

(d) “End-item” means the final product when assembled and ready for issue or deployment.

(e) “Foreign defense sales system” means the enterprise devoted to the transfer of defense articles, services, and training by the United States Government and United States companies to international partners and organizations.

(f) All other terms related to FMS cases shall have the meanings given to them by the SAMM, DSCA 5105.38M.

Sec. 5. General Provisions.

(a) Nothing in this order shall be construed to impair or otherwise affect:

(i) the authority granted by law to an executive department or agency, or the head thereof; or

(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.

(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.

https://www.whitehouse.gov/presidential-actions/2025/04/reforming-foreign-defense-sales-to-improve-speed-and-accountability/

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

Annual Report to Congress on Direct Commercial Sales Authorizations to Foreign Countries and International Organizations for Fiscal Year 2024 as required by Section 655 of the Foreign Assistance Act of 1961, as amended

April 25, 2025: This report documents defense articles and defense services licensed for permanent export under Section 38 of the Arms Export Control Act (AECA), 22 U.S.C. 2778, to each foreign country and international organization during fiscal year (FY) 2024, in response to the requirements in Section 655(b)(3) of the Foreign Assistance Act (FAA) of 1961, as amended. The Department of Defense will report International Military Education and Training activities separately.

The report specifies the aggregate dollar value and quantity of defense articles, and defense services, authorized to each foreign country and international organization during the fiscal year, as well as data on the actual shipments of those licensed transactions. The actual-shipment data shows the total dollar value of all shipments that were authorized and on Page 2 of 4 that exported during the fiscal year to each destination. Authorizations in this report are categorized based on the destination country.

Authorizations applicable to multiple countries in the appendix are included under the designation “Various.” Documentation for shipping purposes requires a definitive destination be declared. Accordingly, actual shipments for those articles approved under the designation “Various” are attributed to the country listed on the shipping documentation.

The reported value of authorizations for defense articles and defense services does not correlate precisely to the value of articles actually transferred during the reporting period. The reasons for this are as follows: Most licenses issued for defense articles are valid for four years and may be used throughout the four years to execute authorized transactions. Similarly, manufacturing license and technical assistance agreements cover a wide range of programmatic activities for multi-year periods (generally exceeding the four-year validity period of defense-article export licenses). Export authorizations furnished in FY 2024 also include certain activities occurring in prior years, because the scope of the Department’s regulatory authority over such agreements continues for as long as these multi-year agreements remain in effect

https://www.pmddtc.state.gov/sys_attachment.do?sys_id=ef6ae6324785aa107ddc0c03e16d43ef

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

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DDTC Name And Address Changes Posted To Website

April 1, 2025, through April 30, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at

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

Change in Name of Churyo Engineering Co., Ltd. to MHI Aero Technologies Co., Ltd. due to acquisition;
Change in Name of Compro Computer Services, Inc. to Aechelon Technology, Inc. due to acquisition;
Change in Name of Toshiba Infrastructure Systems & Solutions Corporation to Toshiba Corporation due to corporate restructuring;
Change in Name of Bollore Logistics SE to CEVA Logistics SA due to acquisition;
Change in Address of Mikuni Aerospace Corporation, Nagoya Sales Office from 1-17-26 Nishiki, Naka-ku, Nagoya, Aichi, Japan to 3-20- 27 Nishiki, Naka-ku, Nagoya, Aichi Prefecture 460-003, Japan;
Change in Name and Address of General Electric International Inc., Kungsgatan 15, Stockholm, Sweden to Arcam AB, Designvagen 2, Molnlycke 435 33, Sweden due to acquisition;
Change in Name of Daher Aerospace SA to Daher Logistics SAS and Daher Business Support SAS due to company spin-off;
Change in Address of OHB Sweden AB, Vidarugatan 6, 164 40 Kista, Sweden to Torshamnsgatan 24, 164 40 Kista, Sweden;
Change in Address of General Dynamics Mission Systems, Inc. and General Dynamics Mission Systems Overseas Company, LLC, from 12450 Fair Lakes Circle, Suite 800, Fairfax, Virginia 22033 to 15036 Conference Center Drive, Suite 400, Chantilly, Virginia 20151;
Change in Address of filal af GE Aviation System North America LLC (“GE Denmark”) from Frederiksborggade 15,3, Kobenhavn 1358, Denmark to Frederiksborggade 15,3, Kobenhavn 1360, Denmark;
Change in Name of Blue Origin, LLC to Blue Origin Manufacturing, LLC due to corporate restructuring;
Change in Name of Multiwerkplaats B.V. to MWP Works due to acquisition;
Change in Name of General Dynamics Mission Systems - Italy S.r.l., General Dynamics Mission Systems Gulf LLC, and General Dynamics Mission Systems Asia-Pacific SDN BHD to Page Europa S.r.l., Page Middle East LLC, and Page Asia Pacific SDN BHD due to acquisition; and
Change in Name of Jacobs Australia Pty Limited to Amentum Australia Proprietary Limited due to acquisition.

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DDTC Frequently Asked Questions (FAQ)

Q: What does it mean to be on one of DDTC's lists of debarred parties?

Q: Why does the purchase documentation have to be issued within one year?

A: This requirement ensures the current validity of the export request. To comply with this requirement it is recommended all purchase documentation must be dated. A letter of explanation must be provided for any purchase documentation not meeting this requirement.

Q: How is a purchase order issued to a subsidiary handled in the license application?

Q: Can I get an agreement in lieu of a brokering authorization?

A: No. In most cases, an agreement does not provide the full authorization for brokering activities. Parties must ensure broker registration and any required approval of brokering activities is obtained prior to brokering activities occurring.

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Ecuador

April 1, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Ecuador has requested to buy M4A1 rifles. The following non-MDE items will also be included: Magpul PMAG M4 magazines; technical manuals; training and support; and other related elements of logistics and program support. The estimated total cost is $64 million. The principal contractor will be determined after case implementation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/ecuador-m4a1-rifles-and-support

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DSCA Notifies Congress of Potential FMS Sale To the Philippines

April 1, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the Philippines has requested to buy sixteen (16) F-16 C Block 70/72 aircraft; four (4) F-16 D Block 70/72 aircraft; twenty-four (24) F110-GE-129D or F100-PW-229 Engines (20 installed, 4 spares); twenty-two (22) Improved Programmable Display Generators (iPDG) (20 installed, 2 spares); twenty-two (22) AN/APG-83 Active Electronically Scanned Array (AESA) Scalable Agile Beam Radars (SABR) (20 installed, 2 spares); twenty-two (22) Modular Mission Computers 7000AH (or available mission computer) (20 installed, 2 spares); twenty-two (22) Embedded Global Positioning System (GPS) Inertial Navigation Systems (INS) (EGI) with Selective Availability Anti-Spoofing Module (SAASM) or M-Code capability and Precise Positioning Service (PPS) (20 installed, 2 spares); eighty-eight (88) LAU-129 guided missile launchers; twenty-two (22) M61A1 anti-aircraft guns (20 installed, 2 spares); twelve (12) AN/AAQ-33 Sniper Advanced Targeting Pods (ATP); twenty-four (24) Multifunctional Information Distribution System-Joint Tactical Radio Systems (MIDS-JTRS); one hundred twelve (112) Advanced Medium Range Air-to-Air Missiles (AMRAAMs) Air Intercept Missile (AIM)-120C-8 or equivalent missiles; four (4) AMRAAM guidance sections; thirty-six (36) Guided Bomb Unit (GBU)-39/B Small Diameter Bombs Increment 1 (SDB-1); two (2) GBU-39(T-1)/B SDB-1 Guided Test Vehicles; forty (40) AIM-9X Block II Sidewinder missiles; thirty-two (32) AIM-9X Block II Sidewinder Captive Air Training Missiles (CATMs); four (4) AIM-9X Block II Sidewinder guidance units; three (3) AIM-9X Block II Captive Air Training Missile (CATM) guidance units; sixty (60) MK-82 500-lb general purpose bombs; sixty (60) MK-84 2,000-lb general purpose bombs; thirty (30) Joint Direct Attack Munition (JDAM) KMU-572 tail kits for GBU-38 or Laser JDAM GBU-54; sixty (60) FMU-152 fuze systems; thirty (30) MAU-210 enhanced computer control groups (ECCG) for GBU-50 Enhanced Paveway II (EP II); and thirty-two (32) MXU-651 air foil groups (AFG) for GBU-50 EP II. The following non-MDE items will also be included: AN/ALQ-254 Viper Shield (VS) electronic warfare (EW) or equivalent systems; AMRAAM CATMs; AIM-9X Sidewinder training missiles and active optical target detectors (AOTD); Infrared Search and Track (IRST) systems; Air Combat Maneuvering Instrument (ACMI) range systems; FMU-139 Joint Programmable Fuzes (JPFs); missile containers; AN/ARC-238 radios; AN/APX-127 or equivalent Advanced Identification Friend or Foe (AIFF) Combined Interrogator Transponders (CIT) with Mode 5; KY-58 and KIV-78 cryptographic devices; AN/PYQ-10 Simple Key Loaders (SKLs); KGV-250X cryptographic devices; Scorpion Hybrid Optical-based Inertial Trackers (HObIT) or Joint Helmet Mounted Cueing Systems II (JHMCS II) helmet mounted displays; night vision devices (NVDs); spare image intensifier tubes; AN/ALE-47 Airborne Countermeasures Dispenser Systems (CMDS); AN/ALE-47 countermeasure processors; AN/ALE-47 sequencer switching units; AN/ALE-47 Control Display Units (CDUs); precision navigation; Joint Mission Planning Systems (JMPS); GPS Antenna System (GAS-1) antenna electronics; Sniper pod pylons; ADU-890 and
ADU-891 adapter units, LAU-117 and LAU-88 Maverick launchers, impulse cartridges, chaff, flares, ammunition, and other bomb components; BRU-57 bomb racks; BRU-61 munitions carriage assemblies; MAU-12 bomb racks and TER-9A triple ejection racks; Common Munitions Built-in-Test (BIT) Reprogramming Equipment (CMBRE); Rackmount Improved Avionics Intermediate Shop (RIAIS); Cartridge Actuated Devices/Propellant Actuated Devices (CAD/PAD); targeting systems; aircraft refurbishment after maintenance training; spare and repair parts, consumables and accessories; repair and return support; aircraft, engine, ground, and pilot life support equipment; classified and unclassified computer program identification number (CPIN) systems; pylons, launcher adapters, weapon interfaces, and bomb and ejection racks; fuel tanks; Precision Measurement Equipment Laboratory (PMEL) and calibration support; National Geospatial-Intelligence Agency (NGA) maps and mapping data; ferry and fuel support; classified and unclassified software and software support; classified and unclassified publications, manuals, and technical documentation; facilities and construction support; simulators and training devices; personnel training and training equipment; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $5.58 billion. The principal contractor will be Lockheed Martin, located in Greenville, SC. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/philippines-f-16-aircraft

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DSCA Notifies Congress of Potential FMS Sale To the Kuwait

April 3, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Kuwait has requested to buy equipment and services required to upgrade and recertify PATRIOT PAC-2 Guidance Enhancement Missiles (GEM) and recertify PATRIOT Guidance Enhancement Missiles-Tactical (GEM-T). The following non-MDE items will be included: sustainment maintenance; special tools, support, and test equipment; repair parts; modification kits; common tools; shop equipment and fixtures; material handling equipment; test support; stockpile reliability testing and inspection; repair and return support; spare parts; training; replacement materials; support from field service representatives, technicians, mechanics, and other support personnel; and other related elements of logistics and program support. The estimated total cost is $400 million. The principal contractor will be RTX Corporation, located in Letterkenny, PA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/kuwait-upgrade-and-recertification-patriot-missiles

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DSCA Notifies Congress of Potential FMS Sale To Australia

April 9, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Australia has requested to buy up to two hundred (200) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM); and up to two hundred (200) AIM-120D-3 AMRAAMs. The following non-MDE items will be included: AMRAAM containers and support equipment; spare parts, consumables and accessories, repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.04 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4150603/australia-aim-120c-and-aim-120d-advanced-medium-range-air-to-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Israel

April 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Israel has requested to buy additional Eitan 8V199TE21-D powerpack engines and engine components that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $85.5 million ($0 in MDE), included Eitan 8V199TE21-D powerpack engines and engine components; U.S. Government and contractor technical assistance; contractor non-recurring engineering; and other related elements of logistics and program support. This notification is for a combined notification of non-MDE Eitan 8V199TE21-D powerpack engines and engine components; U.S. Government and contractor technical assistance; contractor non-recurring engineering; and other related elements of logistics and program support. The estimated total cost is $180 million. The principal contractor will be Rolls-Royce Solutions America, Inc., located in Novi, MI. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4154118/israel-eitan-powerpack-engines

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DSCA Notifies Congress of Potential FMS Sale To the Philippines

April 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Philippines has requested to buy the following defense articles and services: TH-73A training helicopters; aircraft simulator; spare engines; pack up kits; fuel tanks; aircraft hoists and lifts; commercial avionics; commercial flight management systems; commercial Global Positioning Systems; shipping containers; support and test equipment; consumables and accessories; integration and test support; repair and return support; spare and repair parts; unclassified software delivery and support; unclassified publications and technical documentation; personnel training and commercial training equipment; U.S. Government and contractor engineering, technical, logistics, and transportation support services, including in-country representative support; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $120 million. The principal contractor will be AgustaWestland Philadelphia Corporation (Leonardo), located in Philadelphia, PA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4155316/philippines-th-73a-training-helicopters-and-support

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DSCA Notifies Congress of Potential FMS Sale To Morocco

April 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Kingdom of Morocco has requested to buy up to six hundred (600) FIM-92K Stinger Block I missiles. The following non-MDE items will also be included: U.S. Government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $825 million. The principal contractors will be RTX Corporation, located in Tucson, AZ; and Lockheed Martin, located in Syracuse, NY. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4155284/kingdom-of-morocco-fim-92k-stinger-block-i-missiles

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DSCA Notifies Congress of Potential FMS Sale To Ireland

April 23, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ireland has requested to buy thirty-six (36) Lightweight Command Launch Units (LwCLUs) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $8.7 million ($7.9 million in MDE), included forty-four (44) FGM-148 Javelin missiles. This notification is for a combined total of forty-four (44) FGM-148 Javelin missiles and thirty-six (36) Lightweight Command Launch Units (LwCLUs). The following non-MDE items will also be included: missile containers; U.S. Government technical assistance; Enhanced Producibility Basic Skills Trainers (EPBST); training; and other related elements of logistics and program support. The estimated total cost is $46 million. The prime contractors will be the Javelin Joint Venture between Lockheed Martin, located in Orlando, FL, and RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4164095/ireland-fgm-148-javelin-missiles-and-lightweight-command-launch-units

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DSCA Notifies Congress of Potential FMS Sale To The Netherlands

April 25, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Netherlands has requested to buy up to one hundred sixty-three (163) Tomahawk Block V All Up Rounds (AURs); twelve (12) Tomahawk Block IV AURs; up to ten (10) Tactical Tomahawk Weapons Control Systems (TTWCS); and up to two (2) Tomahawk Block IV telemetry missiles. The following non-MDE items will also be included: satellite data link terminals (KIV-18A); integrated secure broadcast systems (KSX-5); communications security devices (KGV-135A); technical, programmatic, engineering, and logistical support for the Tomahawk AUR missiles, TTWCS, and Mission Distribution Software; missile containers; software; hardware; training; training devices; unscheduled missile maintenance; spares; in-service support; communication equipment; operational flight test; publications; engineering and technical expertise to maintain the capability; non-recurring engineering; transportation; and other related elements of logistics and program support. The estimated total cost is $2.19 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. There are known offset requirements associated with this sale. See the attached annex for further details.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4166632/the-netherlands-tomahawk-land-attack-missiles

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DSCA Notifies Congress of Potential FMS Sale To Romania

April 28, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Romania has requested to buy one (1) AN/MPQ-65 Configuration 3+ Increment 3 radar set; one (1) AN/MSQ-132 Engagement Control Station; two (2) M903 launching stations; and one (1) Electrical Power Plant (EPP) III. The following non-MDE items will also be included: launching station modification kits; PATRIOT Advanced Capability-3 (PAC-3) Missile Segment Enhancement launcher conversion kit; generators; generator spare parts; prime movers; spare parts for prime movers; KG-250X encryptor; AN/TPX-57v1 identification friend or foe (IFF); KIV-77 encryptor; personnel communication equipment training; Defense Advanced Global Positioning Systems Receivers (DAGRs); U.S. Government and contractor representative technical assistance; engineering and logistics support services; publications and technical documentation; classified software; classified books and publications; and other related elements of logistics and program support. The estimated total cost is $280 million. The principal contractors will be RTX Corporation, located in Andover, MA, and Lockheed Martin, located in Bethesda, MD. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4167631/romania-patriot-air-defense-system

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DSCA Notifies Congress of Potential FMS Sale To Poland

April 29, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy four hundred (400) AIM-120D3 Advanced Medium-Range Air-to-Air Missiles (AMRAAM); sixteen (16) AIM-120D3 AMRAAM guidance sections, including either Selective Availability Anti-Spoofing Modules or M-Code; and one (1) AIM-120 AMRAAM Instrumented Test Vehicle. The following non-MDE items will also be included: AMRAAM control sections, missile containers, and support equipment; Common Munitions Built-in-Test Reprogramming Equipment (CMBRE); ADU-891 adapter group test sets; KGV-135A encryption devices; Computer Program Identification Numbers (CPINs); spares and repair parts, consumables and accessories, and repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.33 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4168673/poland-aim-120d-advanced-medium-range-air-to-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Kuwait

April 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Kuwait has requested to buy services, including delivery, installation, and upgrade, for PATRIOT Post-Deployment Build (PDB) 8.1. The following non-MDE items will be included: software development; delivery and support; sustainment maintenance; spare and repair parts; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; integration and test support; and other related elements of logistics and program support. The estimated total cost is $425 million. The principal contractor will be RTX Corporation, located in Waltham, MA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4170479/kuwait-patriot-post-deployment-build-81

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DSCA Notifies Congress of Potential FMS Sale To India

April 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of India has requested to buy SeaVision software (including requested software enhancements); Technical Assistance Field Team (TAFT) training; remote software and analytic support; access to SeaVision documentation; and other related elements of logistics and program support. The estimated total cost is $131 million. The principal contractor will be Hawkeye 360, located in Herndon, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/Congressional-Notification-Archive/Article/4170460/india-indo-pacific-maritime-domain-awareness

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

BIS Nominee Suggests 50% Rule for Entity List

April 11, 2025: Landon Heid, the President’s nominee to be assistant secretary of commerce for export administration, said April 10 that he wants the Bureau of Industry and Security to wage a “continuous battle every single day” to prevent China from obtaining restricted U.S. technology. He suggested that he wants to make subsidiaries automatically subject to Entity List restrictions, similar to OFAC’s 50% rule.

https://exportcompliancedaily.com/article/2025/04/11/bis-nominee-suggests-50-rule-for-entity-list-2504100036?BC=bc_680120417547a

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Commerce Launches Section 232 Investigation on Imports of Medium-Duty and Heavy-Duty Trucks and their parts

April 23, 2025: The Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862) (“Section 232”), to determine the effects on the national security of the imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts.

The Bureau of Industry and Security (BIS) examined the current quantities and circumstances of these imports to determine if it threatens to impair U.S. national security and whether action is needed to address any such threat. Protection of U.S. national security and economic interests remains the President’s first priority, and this investigation will ensure American truck manufacturing remains protected.

Under Secretary of Commerce for Industry and Security Jeffrey Kessler released the following statement:

“A strong and resilient automotive and truck industry is vital to our national security. Under President Trump’s leadership, the Commerce Department will work to support this vital sector and carefully assess the risks posed by external threats and supply chain vulnerabilities.”

Interested parties are invited to submit written comments, data, analyses, or other information pertinent to the investigation to the Department of Commerce’s (Department) Bureau of Industry and Security (BIS), Office of Strategic Industries and Economic Security.

https://www.bis.gov/press-release/commerce-launches-section-232-investigation-imports-medium-duty-heavy-duty-trucks-their-parts

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Commerce Launches Section 232 Investigation on Imports of Processed Critical Minerals and Derivative Products

April 23, 2025: The Department of Commerce initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862) (“Section 232”), to evaluate the effects of processed critical minerals and their derivative products on U.S. national security.

Critical minerals, including rare earth elements, are important production inputs required for both civilian and defense-related applications. However, China currently dominates the global market for processing critical minerals and is the leading producer of 30 out of 44 critical minerals. In addition, China is expanding its influence by acquiring mining concessions and operations around the world.

Through this Section 232 investigation, the Bureau of Industry and Security (BIS) is evaluating the foreign sources of processed critical minerals and their derivative products and assessing the associated risks. BIS is also analyzing current and potential U.S. capabilities to process critical minerals and their derivative products. This is an important step in securing America’s mineral future and prioritizing national security.

U.S. Under Secretary of Commerce for Industry and Security Jeffrey Kessler released the following statement:

“The United States should not allow foreign adversaries to have a chokehold on critical inputs for our economy and defense industrial base. Under President Trump’s leadership, the Commerce Department will carefully assess the risks posed by external threats and supply chain vulnerabilities.”

Interested parties are invited to submit written comments, data, analyses, or other information pertinent to the investigation to BIS’s Office of Strategic Industries and Economic Security.

https://www.bis.gov/press-release/commerce-launches-section-232-investigation-imports-processed-critical-minerals-derivative-products

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U.S. Census Bureau

Update to the Automated Export System Trade Interface Requirements – Appendix U – HTS/Schedule B Classifications Requiring Used Vehicle Reporting

April 7, 2025:

CSMS # 64646715 - Update to the Automated Export System Trade Interface Requirements – Appendix U – HTS/Schedule B Classifications Requiring Used Vehicle Reporting.

Update to the Automated Export System Trade Interface Requirements (AESTIR) – Appendix U – HTS/Schedule B Classifications Requiring Used Vehicle Reporting has been posted to CBP.gov.

The following HTS/Schedule B code numbers have been added: 8432.80.0010.

The following HTS/Schedule B code numbers have been removed: 8708.30.0050.

Documentation is available under the ACE AESTIR, Appendix U in the AES webpage which can be located at: https://www.cbp.gov/document/guidance/appendix-u-htsschedule-b-classifications-requiring-used-vehicle-reporting.

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How to Resolve Common AES Response Messages

April 21, 2025:

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

Response Code: 649

Narrative: Quantity 1 Cannot Exceed Shipping Weight

Severity: Fatal

Reason: The Unit of Measure 1 for the reported Schedule B/HTS requires kilograms and Quantity 1 exceeds the Shipping Weight.

Resolution: For the Schedule B/HTS reported, Quantity 1 must be reported in kilograms. Quantity 1 in kilograms cannot exceed the Shipping Weight.

Verify the Quantity 1 and Shipping Weight, correct the shipment and resubmit.

For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.

As a reminder, filers have multiple resources that they can use when filing EEI to the AES.

LATEST SANCTIONS FINES & PENALTIES

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

Fines and Penalties

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

April 2, 2025: A seven-count indictment was unsealed in federal court in Brooklyn charging José Adolfo Macías Villamar, also known as “Fito,” with international cocaine distribution conspiracy; international cocaine distribution; using firearms in furtherance of drug trafficking; smuggling firearms from the United States; and straw purchasing of firearms conspiracy. Since at least 2020, he has been the leader of Los Choneros, one of Ecuador’s most violent drug trafficking and transnational criminal organizations. The defendant is not in U.S. custody.

https://www.justice.gov/usao-edny/pr/jose-adolfo-fito-macias-villamar-leader-los-choneros-transnational-criminal and

https://www.bis.gov/news-updates

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April 2, 2025: An indictment was unsealed charging Mohammad Jawaid Aziz, also known as Jawaid Aziz Siddiqui and Jay Siddiqui, 67, of Pakistan and Canada, with conspiracy to violate U.S. export laws and violating U.S. export laws. Siddiqui was arrested on March 21 in the Western District of Washington while attempting to cross into the United States from Canada. He remains detained, pending transfer to the District of Minnesota.

https://www.justice.gov/opa/pr/dual-pakistani-canadian-national-arrested-years-long-scheme-circumvent-us-export-control and

https://www.bis.gov/news-updates

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April 2, 2025: Oleg Sergeyevhich Patsulya, a Russian national, was sentenced to 70 months, or nearly six years, in prison for his role in a conspiracy to export controlled aviation technology to Russia and to launder money in connection with the illegal export scheme. In December 2024, Patsulya’s co-conspirator, Russian national Vasilii Sergeyevich Besedin, was sentenced to two years in prison for his role in the scheme.

https://www.justice.gov/opa/pr/leader-export-control-evasion-scheme-sentenced-70-months-prison

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April 4, 2025: 90 Fed. Reg. 14783: Pursuant to section 766.24 of the Export Administration Regulations, 15 CFR parts 730-774, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, through its Office of Export Enforcement (“OEE”), has requested the issuance of an Order temporarily denying, for a period of 180 days, the export privileges under the Regulations of: ExHigh Air Space Ltd. (“ExHigh”), Geoffrey Chune Omariba (“Chune”), and Nader Ali Saboori Haghighi (“Haghighi”), (collectively, the “Respondents”). OEE's request and related information indicate that these parties are located in Nairobi, Kenya, and Belgrade, Serbia, at the respective addresses listed on the caption page of this order. OEE's request and related information further indicates that the Respondents have obtained, and continue to engage in attempts to obtain, controlled aircraft parts from the United States in order to divert those items to Russia contrary to the requirements of the Regulations.

https://www.federalregister.gov/documents/2025/04/04/2025-05803/order-temporarily-denying-export-privileges

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April 30, 2025: The Justice Department announced that it has declined the prosecution of Universities Space Research Association (USRA) after it self-disclosed to the Department’s National Security Division (NSD) criminal violations of U.S. export control laws committed by its former employee, Jonathan Soong. Soong pleaded guilty to willfully violating the Export Administration Regulations (EAR) by exporting U.S. Army-developed aviation software to a university in the People’s Republic of China (PRC) that had been placed on the Commerce Department’s Entity List and was sentenced to 20 months in prison.

https://www.justice.gov/opa/pr/justice-department-declines-prosecution-company-self-disclosed-export-control-offenses

Sanctions

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

April 3, 2025: the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated list of foreign companies that have made boycott-related requests, including requests to comply with the Arab League boycott of Israel. BIS added 30 parties, in addition to removing 18 entities who certified that they have stopped making boycott-related requests in transactions with U.S. persons. BIS maintains anti-boycott regulations that discourage and, in certain circumstances, prohibit U.S. persons or businesses from participating in unsanctioned foreign boycotts, focusing on the Arab League boycott of Israel.

Parties Added to the Requester List:

REQUESTER	LOCATION
ATEL TEKNOLOJI VE SAVUNMA SANAYI	TURKEY
B.M. NAGANO INDUSTRIES	MALAYSIA
BASHUNDHARA READYMIX AND CONSTRUCTION INDUSTRIES LTD	BANGLADESH
BENCHMARK ELECTRONICS (M) SDN BHD	MALAYSIA
BRITISH AMERICAN TOBACCO BANGLADESH COMPANY LTD	BANGLADESH
DHL Global Forwarding Qatar W.L.L.	QATAR
EOLANE MALAYSIA SDN BHD	MALAYSIA
INTEC DISTRIBUTIONS LTD.,	BANGLADESH
INTERSCIENCE TECHNOLOGIES	BANGLADESH
ITG ELECTRONICS	MALAYSIA
J.K. SPINNING MILLS LTD	BANGLADESH
KUEHNE-NAGEL	TURKEY
KUWAIT INVESTMENT AUTHORITY	KUWAIT
KUWAIT PETROLEUM COMPANY	KUWAIT
LEADER SPORT LLC	UNITED ARAB EMIRATES
LOTTE CHEMICAL PAKISTAN LIMITED	PAKISTAN
MASHREQ BANK KUWAIT BRANCH	KUWAIT
MOH / THE STATE COMP. FOR MARKETING DRUGS MEDICAL APPLIANCES	IRAQ
NATIONAL HEART FOUNDATION OF BANGLADESH	BANGLADESH
PENTAMASTER EQUIPMENT MFG	MALAYSIA
PETROCHEMICAL INDUSTRIES COMPANY (K.S.C.)	KUWAIT
PETROFAC INTERNATIONAL (UAE) LLC	ALGERIA
SANMINA-SCI SYSTEMS	MALAYSIA
SAUDIA TECHNIC	SAUDI ARABIA
SMART INDUSTRIES	MALAYSIA
SPECIALIZED SECURITY SYSTEMS CO. WII	KUWAIT
SPM OIL AND GAS	PAKISTAN
STANDARD CHARTERED BANK	PAKISTAN
UNITED BANK LIMITED	PAKISTAN
WATER & ENVIRONMENTAL TECHNOLOGY COMPANY, LLC	SAUDI ARABIA

https://www.bis.gov/press-release/bis-updates-boycott-requester-list-8 and

https://www.bis.gov/press-release/bis-updates-boycott-requester-list-8

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April 25, 2025: 90. Fed. Reg. 17339; The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL). Of the 18 persons being added: five are under the destination of China, People's Republic of (China); six are under the destination of Finland; three are under the destination of Türkiye; two are under the destination of Kazakhstan; one is under the destination of Italy; and one is under the destination of the United Kingdom. BIS is also amending the EAR by removing five persons from the UVL. Of the five persons being removed, three are under the destination of China and two are under the destination of the United Arab Emirates.

Pursuant to § 744.15(c) of the EAR, this rule adds 18 persons to the UVL by amending supplement no. 6 to part 744 of the EAR to include their names and addresses. This final rule implements the decision to add the following 18 persons located in the following destinations to the UVL:

Arctic Star Co., Ltd.; Henixio Aviation Co., Ltd.; Shusum Construction Ltd.; Sino-World International Co., Ltd.; and Vauxhall International Co., Ltd., under the destination of China;
Buran TMI; Finland Multi Center FMC OY; Finnalliance OY; Inmargo OY; Karjalan Puutyo; and MM Cargo OY, under the destination of Finland;
Euro Servizi Elettromeccanici Industriali SEI., under the destination of Italy;
EltexAlatau and Inter-Traid Electro, under the destination of Kazakhstan;
Bagil Havacilik, Basak Traktor, and Ozkanlar Grup Makine AS, under the destination of Türkiye; and
Identiparts Ltd., under the destination of the United Kingdom.

https://www.federalregister.gov/documents/2025/04/25/2025-07185/revisions-to-the-unverified-list

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

April 1, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the U.S. Department of Justice, targeted a network of six entities and two individuals based in Iran, the United Arab Emirates (UAE), and the People’s Republic of China (PRC) responsible for the procurement of unmanned aerial vehicle (UAV) components on behalf of Iran-based Qods Aviation Industries (QAI)—a leading manufacturer for Iran’s UAV program. This network has also facilitated procurement for other entities in Iran’s military-industrial complex, to include Iran Aircraft Manufacturing Industrial Company (HESA) and Shahid Bakeri Industrial Group (SBIG). This action marks the second round of sanctions targeting Iranian weapons proliferators since the President issued National Security Presidential Memorandum 2 on February 4, 2025, ordering a campaign of maximum pressure on Iran.

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

Akbari, Hossein of Iran; and
Yousefnejad, Abbas of Iran.

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

Diamond Castle Elctronics Trading LLC of the United Arab Emirates;
Future Trends Goods Wholesalers LLC of the United Arab Emirates;
Infracom Communications Network FZE of the United Arab Emirates;
Phenomena International General Trading LLC of the United Arab Emirates;
Rah Roshd International Trade Exchanges Development of Iran; and
Zibo Shenbo Machinelectronics Co LTD of China.

https://ofac.treasury.gov/recent-actions/20250401 and

https://home.treasury.gov/news/press-releases/sb0066

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April 2, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against a network of Houthi financial facilitators and procurement operatives working in coordination with Sa’id al-Jamal, a senior Houthi financial official backed by Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). This network has procured tens of millions of dollars’ worth of commodities from Russia, including weapons and sensitive goods, as well as stolen Ukrainian grain, for onward shipment to Houthi-controlled Yemen. Additionally, OFAC has identified eight digital asset wallets used by the Houthis to transfer funds associated with their activities.

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

Beliyakov, Yuri Vladimirovich of Russia;
Ghairat, Hushang of Afghanistan;
Ghairat, Sohrab of Afghanistan;
Jafari, Hassan of Iran; and
Vidanov, Vyacheslov Vladimirovich of Russia.

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

AM ASIA M6 LTD of China;
LLC Edison of Russia;
LLC Kolibri Group Russia; and
LLC Sky Frame of Russia.

The following vessel has been added to OFAC’s SDN List:

AM Theseus (UBKZ6) Bulk Carrier Russia flag; MMSI 273254900 (vessel).

https://ofac.treasury.gov/recent-actions/20250402

https://home.treasury.gov/news/press-releases/sb0068

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April 2, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has released Quarterly Reports of Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by OFAC under Section 906(a)(1) of the TSRA from October through December 2024. Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran under the specific licensing regime set forth in Section 906 of the TSRA.

https://ofac.treasury.gov/ofac-license-application-page/trade-sanctions-reform-and-export-enhancement-act-of-2000-tsra-program/trade-sanctions-reform-and-export-enhancement-act-of-2000-tsra-reports-to-congress and

https://ofac.treasury.gov/media/934191/download?inline

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April 7, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued Russia-related General License 13M, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.”

Additionally, OFAC has updated two Frequently Asked Questions (FAQ 999, FAQ 1118).

GENERAL LICENSE NO. 13M: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”

S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, July 9, 2025.

FAQ 999:

Q: What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

A: OFAC issued Russia-related General Licenses (GLs) 8L and 115A to authorize the wind-down of certain energy-related transactions and civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive (see FAQs 976 and 977).

OFAC issued GL 13M to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13M, see FAQ 1118.

OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.

Note that GL 8L, GL 13M, GL 14, and GL 115A continue to authorize against the Russia-related Sovereign Transactions Directive.

FAQ 1118:

Q: As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13M authorize transactions that involve the payment of this exit tax?

A: The Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, “Directive 4 entities”). As noted in FAQ 1002, this includes both direct and indirect transactions.

OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called “exit taxes” imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.

GL 13M authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13M.

Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an “exit tax” should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC’s Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.

While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.

https://ofac.treasury.gov/faqs/1118 and

https://ofac.treasury.gov/recent-actions/20250407

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April 9, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated five entities, and one individual based in Iran for their support to key entities that manage and oversee Iran’s nuclear program, including the Atomic Energy Organization of Iran (AEOI) and the AEOI-subordinate Iran Centrifuge Technology Company (TESA). This action, which targets entities procuring, or manufacturing, critical technologies for TESA and AEOI, is taken in furtherance of U.S. policy that Iran be denied a nuclear weapon, as stated in National Security Presidential Memorandum 2.

The following individual has been added to OFAC’s SDN List:

Mosallat, Majid of Iran.

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

Atbin Ista Technical And Engineering Company of Iran;
Azarab Industries Co. of Iran;
Pars Reactors Construction and Development Company of Iran;
Pegah Aluminum Arak Company of Iran; and
Thorium Power Company of Iran.

https://ofac.treasury.gov/recent-actions/20250409

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

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April 9, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Mexican national Jesus Alfredo Beltran Guzman, a key leader of the Beltran Leyva Organization (BLO), for playing a significant role in the trafficking of illicit drugs, including fentanyl, cocaine, heroin, and methamphetamine, into the United States. One of the most powerful drug trafficking organizations in the world, the BLO is heavily involved in the transportation and distribution of deadly drugs, including fentanyl, to the United States, and has been one of the largest suppliers of cocaine to the U.S. market for over two decades. OFAC carried out this investigation in coordination with the Federal Bureau of Investigation (FBI) and Drug Enforcement Administration (DEA).

The following individual has been added to OFAC’s SDN List:

Beltran Guzman of Mexico.

https://ofac.treasury.gov/recent-actions/20250409

https://home.treasury.gov/news/press-releases/sb0076

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April 10, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated United Arab Emirates (UAE)-based Indian national Jugwinder Singh Brar (Brar), who owns multiple shipping companies that boast a fleet of nearly 30 vessels, many of which operate as part of Iran’s “shadow fleet.” OFAC also designated two UAE- and two India-based entities that own and operate Brar’s vessels that have transported Iranian oil on behalf of the National Iranian Oil Company (NIOC) and the Iranian military. Brar’s vessels engage in high-risk ship-to-ship (STS) transfers of Iranian petroleum in waters off Iraq, Iran, the UAE, and the Gulf of Oman. These cargoes then reach other facilitators who blend the oil or fuel with products from other countries and falsify shipping documents to conceal links to Iran, allowing these cargoes to reach the international market.

The following individual has been added to OFAC’s SND List:

Brar, Jugwinder Singh of the United Arab Emirates.

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

B And P Solutions Private Limited of India;
Global Tankers Private Limited of India;
Glory International FZ-LLC of the United Arab Emirates;
Guangsha Zhoushan Energy Group Co., Ltd of China;
Marziya Shipping OPC Pvt Ltd of India;
Prime Tankers LLC of the United Arab Emirates;
Rising Phoenix Provider NV of Suriname; and
Valiant Marine Ventures FZE of the United Arab Emirates.

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

Amor (TJMC800) Crude Oil Tanker Cameroon flag; MMSI 613884000 (vessel);
Chil 1(C5J280) Chemical/Oil Tanker Gambia flag; MMSI 629009268 (vessel);
Global Ace (3FJW3) Chemical/Oil Tanker Panama flag; MMSI 374808000 (vessel);
Global Angel (3FVC9) Oil Products Tanker Panama flag; MMSI 353283000 (vessel);
Global Asphalt (3FZQ3) Oil Products Tanker Panama flag; MMSI 354816424 (vessel);
Global Beauty (3E6819) Chemical/Products Tanker Panama flag; MMSI 352004530 (vessel);
Global Crest (3FHI8) Crude Oil Tanker Panama flag; MMSI 372463000 (vessel);
Global Dignity (3E2062) Chemical/Products Tanker Panama flag; MMSI 352898795 (vessel);
Global Dominance (V2YZ5) Bunkering Tanker Antigua & Barbuda flag; MMSI 305290000 (vessel);
Global Eagle (D6A3537) Chemical/Products Tanker Comoros flag; MMSI 620999538 (vessel);
Global Elegance (E5U4389) Chemical/Oil Tanker; Former Vessel Flag Cook Islands; MMSI 518998409 (vessel);
Global Emerald (3E2462) Products Tanker Panama flag; MMSI 352001105 (vessel);
Global Everest (3EUO4) Oil Products Tanker Panama flag; MMSI 352995000 (vessel);
Global Falcon (T8A4956) Chemical/Oil Tanker Palau flag; MMSI 511101536 (vessel);
Global Genesis (E5U3771) Oil Products Tanker; Former Vessel Flag Cook Islands; MMSI 518100860 (vessel);
Global Hawk (E5U3877) Chemical/Oil Tanker; Former Vessel Flag Cook Islands; MMSI 518100966 (vessel);
Global Maharani (8P2426) Oil Products Tanker Barbados flag; MMSI 314932000 (vessel);
Global Peace (E5U3881) Oil Products Tanker Cook Islands flag; MMSI 518100969 (vessel);
Global Peak (3FBM7) Products Tanker Panama flag; MMSI 354117000 (vessel);
Global Rani (T8A4955) Chemical/Oil Tanker Palau flag; MMSI 511101535 (vessel);
Global Star (3FYM8) Chemical/Oil Tanker Panama flag; MMSI 354068000 (vessel);
Global Star I (3E4656) Oil Products Tanker Panama flag; MMSI 352002878 (vessel);
Harmony (8PVO9) Oil Products Tanker Barbados flag; MMSI 314825000 (vessel);
Luanda 1(3FWF5) Anchor Handling Vessel Panama flag; MMSI 357029000 (vessel);
Mirage (8P2465) Chemical/Oil Tanker Barbados flag; MMSI 314963000 (vessel);
Nadiya (3E3423) Oil Products Tanker Panama flag; MMSI 352001151 (vessel);
Ocean Princess 1 (3EVR9) Oil Products Tanker Panama flag; MMSI 373094000 (vessel);
Purna (C5J300) Oil Products Tanker Gambia flag; MMSI 629000928 (vessel);
Simran (HO4539) Oil Products Tanker Panama flag; MMSI 356762000 (vessel); and
Virgo (C5J448) Crude Oil Tanker Gambia flag; MMSI 629009436 (vessel).

https://ofac.treasury.gov/recent-actions/20250410

https://home.treasury.gov/news/press-releases/sb0082

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April 15, 2025: The Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four individuals affiliated with La Nueva Familia Michoacana (LNFM), a Mexican cartel designated as a Foreign Terrorist Organization and a Specially Designated Global Terrorist, that has poisoned Americans by trafficking fentanyl and other illicit drugs into the United States. LNFM’s crimes also include the smuggling of illegal aliens into the United States and violence against its rivals and Mexican security forces, utilizing drones and bombs in addition to conventional firearms. Those sanctioned, all of whom are siblings, include the group’s notorious co-leaders: Johnny Hurtado Olascoaga and Jose Alfredo Hurtado Olascoaga.

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

Hurtado Olascoga, Adita of Mexico; and
Hurtado Olascoga, Ubaldo of Mexico.

https://ofac.treasury.gov/recent-actions/20250415 and

https://ofac.treasury.gov/media/934231/download?inline=

https://home.treasury.gov/news/press-releases/sb0087

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April 16, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a China-based independent “teapot” refinery Shandong Shengxing Chemical Co., Ltd. for its role in purchasing more than a billion dollars’ worth of Iranian crude oil, including from a front company for Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). OFAC also imposed additional sanctions on several companies and vessels responsible for facilitating Iranian oil shipments to China as part of Iran’s “shadow fleet.”

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued an Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion.

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

Bestla Company Limited of the Marshall Islands;
Civic Capital Shipping Inc. of Panama;
Dexiang Shipping Co., Limited of China;
Oceanic Orbit Incorporated of Panama;
Pro Mission SDN BHD of Malaysia;
Shadong Shengxing Chemical Co., Ltd. of China; and
Starboard Shipping Inc. of Panama City.

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

Bestla (3E6593) Crude Oil Tanker Panama flag; MMSI 352003044 (vessel);
Egret (3E2524) Crude Oil Tanker Panama flag; MMSI 352001512 (vessel);
Nyantara (3E2243) Crude Oil Tanker Panama flag; MMSI 352002259 (vessel);
Rani (3EED4) Crude Oil Tanker Panama flag; MMSI 354907000 (vessel); and
Reston (TJ4HG) Crude Oil Tanker Cameroon flag; MMSI 613464706 (vessel).

https://ofac.treasury.gov/recent-actions/20250416

https://home.treasury.gov/news/press-releases/sb0090

https://ofac.treasury.gov/media/934236/download?inline

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April 17, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Yemen-based International Bank of Yemen Y.S.C. (IBY) for its financial support to Ansarallah, commonly known as the Houthis, which is part of the Iran threat network. As part of this designation, OFAC sanctioned key leaders or officials of IBY, Kamal Hussain Al Jebry, Ahmed Thabit Noman Al-Absi, and Abdulkader Ali Bazara. The designation of IBY complements the whole-of-government effort to stop Iran-backed Houthi attacks against commercial shipping in the Red Sea.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Counter Terrorism General License 33, "Authorizing the Wind Down of Transactions Involving International Bank of Yemen (IBY)."

GENERAL LICENSE NO. 33: “Authorizing the Wind Down of Transactions Involving International Bank of Yemen (IBY)”

(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), that are ordinarily incident and necessary to the wind down of any transaction involving International Bank of Yemen (IBY), or any entity in which IBY owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, May 17, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the GTSR.

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

Al Jerby, Kamal Hussein of Yemen;
Al-Absi, Ahmed Thabit Noman of Yemen; and
Bazra, Abdulkader, Ali of Yemen.

The following entity has been added to OFAC’s SDN List:

International Bank of Yemen Y.S.C. of Yemen.

https://ofac.treasury.gov/recent-actions/20250417 and

https://ofac.treasury.gov/recent-actions/20250416

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April 22, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Iranian national and liquified petroleum gas (LPG) magnate Seyed Asadoollah Emamjomeh and his corporate network, which is collectively responsible for shipping hundreds of millions of dollars’ worth of Iranian LPG and crude oil to foreign markets. Emamjomeh’s expansive network includes a vessel, the TINOS I, which intended but failed to load cargo in 2024 off the coast of Houston, Texas. In addition to crude oil, LPG continues to be a major source of revenue for the Iranian regime, the proceeds of which fund Iran’s nuclear and advanced conventional weapons programs, as well as regional proxy groups and partners such as Hizballah, the Houthis, and Hamas.

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

Emamjomeh, Meisam of the United Arab Emirates; and
Emamjomeh, Seyed Asadoollah of the United Arab Emirates.

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

Arsa Gas Company of Iran;
Caspian Petrochemical Fze of the United Arab Emirates;
Nilgon Parsa Caspian Shipping Company of Iran;
Parsa Fidar Paydar Engineering and Technology Company of Iran;
Parsa Salakh Qeshm Idustrial Complex of Iran;
Parsa Trabar Caspian International Transportation Company of Iran;
Parsa Trabar Persia International Transportation Company of Iran;
Pasar Gas Company of Iran;
Pasar Gas Novin Trading Company of Iran;
Pearl Petrochemical Fze of the United Arab Emirates;
Petro Parsa Caspian Iranian Company of Iran; and
Worldwide LPG Limited of the United Kingdom.

The following vessel has been added to OFAC’s SDN List:

Tinos I (3E5261) LPG Tanker Panama flag; MMSI 352003638 (vessel).

https://ofac.treasury.gov/recent-actions/20250422

https://home.treasury.gov/news/press-releases/sb0093

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April 28, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted three vessels and their owners for providing support to Ansarallah, commonly known as the Houthis, which is part of the Iranian regime’s network of terrorist proxies and partners. The group has deployed missiles, unmanned aerial vehicles, and naval mines to attack commercial shipping interests in the Red Sea, threatening global freedom of navigation and the integrity of international commerce. The Houthis also profit significantly from the shipment of goods through ports they control, profiting, in particular, from the discharge of refined petroleum products.

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

Bagsak Shipping Inc of Mauritius;
Great Success Shipping Co of Lebanon; and
Zaas Shipping & Trading Co of Lebanon.

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

Maisan (3E4995) Products Tanker Panama flag; MMSI 352002675 (vessel);
Tulip Bz (T7AV5) LPG Tanker San Marino flag; MMSI 268249300 (vessel); and
White Whale (H9HR) Crude/Oil Products Tanker Panama flag; MMSI 374932000 (vessel).

https://ofac.treasury.gov/recent-actions/20250428

https://home.treasury.gov/news/press-releases/sb0113

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April 29, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six entities and six individuals based in Iran and the People’s Republic of China (PRC) for their role in a network procuring ballistic missile propellant ingredients on behalf of Iran’s Islamic Revolutionary Guard Corps (IRGC). This network has facilitated the procurement of sodium perchlorate and dioctyl sebacate from the PRC to Iran. Sodium perchlorate is used to produce ammonium perchlorate, which is controlled by the Missile Technology Control Regime (MTCR), a multilateral political understanding among states that seek to limit the proliferation of missiles and missile technology. Both ammonium perchlorate and dioctyl sebacate are chemicals usable in solid propellant rocket motors, which are commonly used for ballistic missiles.

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

Asgari, Mohammed of Iran;
Modarres Fathi, Forough of Iran;
Pour Kazemi, Abbas of Iran;
Zargar Bab Aldashti, Abed of Iran;
Zagar Bab Aldashti, Hamed of Iran; and
Zagar Bab Aldashti, Zahra of Iran.

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

China Chlorate Tech Co Limited of China;
Dongying Weiaien Chemical Co Ltd of China;
Saman Tejarat Barman Trading Company of Iran;
Shenzhen Amor Logistics Co Ltd of China;
Yanling Chuanxing Chemical Plant General Partnership of China; and
Yanling Lingfeng Chlorate Co Ltd of China.

https://ofac.treasury.gov/recent-actions/20250429

https://home.treasury.gov/news/press-releases/sb0116

APRIL 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

MARCH 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through March 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

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

REGULATORY UPDATES

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

30-Day Notice of Proposed Information Collection: Application/License for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Related Classified Technical Data

March 14, 2025: 90 Fed. Reg. 11640: The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995, the Department of State requested comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment.

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DDTC Name And Address Changes Posted To Website

March 3 through March 21, 2025: 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:

Change in Address of PVP Advanced EO Systems, Inc. from 14312 Franklin Avenue, Suite 100, Tustin, CA 92780 to 26776 Simpatica Circle, Lake Forest, CA 92680;
Change in Address of Capgemini UK Plc from No 1 Forge End, Woking, Surrey, GU21 6DB, United Kingdom to 95 Queen Victoria Street, London, EC4V 4HN, United Kingdom;
Change in Name of Airholding S.A. to Embraer Portugal, S.A due to acquisition;
Change in Name of Mitsubishi Electric Logistics Corporation to MD Logis Corporation due to acquisition.
Change in Name of subsidiaries of Curtiss-Wright Corporation due to corporate restructuring;

Dy4, Inc.	Curtiss-Wright DS, Inc.
Curtiss-Wright Controls Electronic Systems, Inc,
Pacific Star Communications, Inc.
Tactical Communications Group, LLC
Teletronics Technology Corporation
Acra Control Inc.

Change in Name of ELEB Equipamentos Ltda. to Embraer, Brazil due to acquisition;
Change in Name and Address of Econocom Infogerance System, 21, avenue Descarter – Immeuble Astrale, Le Plessis-Robinson, France 92350 to Econocom Workplace Infra Innovation, 40, quai de Dion Bouton, Puteaux, France 92800 due to corporate restructuring;
Change in Name of Compro Computer Services, Inc. to Aechelon Technology, Inc. due to acquisition;
Change in Address of ALTEN S.A. from 40, Avenue Andre Morizet, 92100 Boulogne-Billancourt, FRANCE to ALTEN S.A., 221 Bis, Boulevard Jean Jaures, 92100 Boulogne-Billancourt, FRANCE.
Change in Address of Mikuni Aerospace Corporation, Nagoya Sales Office address from 1-17-26 Nishki, Naka-ku, Nagoya, Aichi, Japan to 3-20- 27 Niskiki, Naka-ku, Nagoya, Aichi Prefecture 460-003, Japan.
Change in Name of CPI International, Inc. to CPI Electron Device Business, Inc. due to corporate restructuring.

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DDTC Frequently Asked Questions (FAQs)

Q: What are the License Status Definitions?

Draft

License request that has not been signed and submitted for a company.

Awaiting Signature

The license request is waiting for the Empowered Official’s review and signature.

Submitted

Empowered Official has signed the license request and is sent to DDTC for review.

In Review

DDTC has received and is reviewing the license request.
The license request status can be found in the Track Status page and the user must be part of an access group containing that license request, in order to see it.

Final

The license request has been fully processed and will be displayed in Track Status.

Rejected

The license request has been rejected by DDTC.

Q: If I am exporting an aircraft that is controlled under Category VIII(a), regardless of whether it is a bomber, fighter, or attack helicopter, must I individually itemize all of the inclusive systems (e.g., electronics, folding wings, batteries, weapons, etc.) in Blocks 9 through 12 as separate items on the DSP 5 license?

A: No for items physically (mechanically, electronically, etc.) incorporated into the aircraft. This does not include spare parts, components, etc. that are to accompany the aircraft during shipment, as these items must be accounted for separately as their own unique line item(s).

Q: What is "DECCS"?

A: “DECCS” stands for Defense Export Control and Compliance System. It is DDTC’s cloud-based modernization replacement of the DTRADE and EFS systems.

Q: How does the § 126.7 exemption work?

A: The International Traffic in Arms Regulations (ITAR) § 126.7 exemption simplifies the transfer of ITAR-controlled defense articles, including technical data, the performance of defense services, and engaging in brokering activities between and among Australia, the United Kingdom, and the United States within an approved Authorized User group of government, private sector, and research and academic entities. When all requirements are met, parties may engage in such activities without the need for additional Directorate of Defense Trade Controls (DDTC) authorization. More information on who is an Authorized User is available in a corresponding FAQ.

Q: Do I need to amend my DDTC authorizations if they only contain items moving from on USML category to another?

A: No. Both agreements and licenses are valid until their expiration. However, if a license is to be amended for reasons unrelated to Export Control Reform, then the category designations must be updated as well. For agreements, if a major amendment to an agreement is submitted, category designations must be updated; but if a minor amendment is submitted, category designations do not necessarily need to be updated. Furthermore, during the transition period, when information on an In Furtherance Of license does not match that which was presented in its parent agreement, the applicant should note the disparities on the cover letter (15.1) for that license. For example: “Gas turbine engines formerly designated USML Category VIII(b) here designated as Cat XIX(a).”

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REMINDER: ITS 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 2024

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Japan

March 10, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Japan has requested to buy equipment and services in support of its indigenous Hyper Velocity Gliding Projectiles (HVGP) capability, including test preparation, test, and transportation support; coordination meetings in the United States and Japan; etc. The estimated total cost is $200 million. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to Japan.

https://www.dsca.mil/press-media/major-arms-sales/japan-hyper-velocity-gliding-projectiles-capability-support

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DSCA Notifies Congress of Potential FMS Sale To Australia

March 10, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Australia has requested to buy fifty-four (54) Guided Multiple Launch Rocket System-Alternate Warhead (GMLRS-AW) rounds. The following non-MDE items will also be included: telemetry kits; engineering services; technical assistance; and other related logistics and program support. The estimated total cost is $91.2 million. The principal contractors will be Lockheed Martin, located in Grand Prairie, TX; and Lockheed Martin, Australia. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/australia-guided-multiple-launch-rocket-system-alternate-warhead

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DSCA Notifies Congress of Potential FMS Sale To Australia

March 18, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Australia has requested to buy MJU-61 decoy flares; MJU-64 decoy flares; MJU-66 flare countermeasures; MJU-76 flare countermeasures; RR-198A/L chaff cartridges; CCU-145/A impulse cartridges; other support equipment (MK-3 pallet); U.S. Government and contractor technical assistance; and other related elements of logistics and program support. The estimated total cost is $165 million. The principal contractors will be Kilgore Flares Company, LLC, located in Toone, TN; Armtec Countermeasures Company, located in Coachella, CA; Alloy Surface Company, Inc, located in Aston, PA; and CCI Capco LLC, located in Grand Junction, CO. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/australia-countermeasures-chaff-and-impulse-cartridges

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DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia

March 18, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy two thousand (2,000) Advanced Precision Kill Weapon Systems (APKWS). The following non-MDE items will be included: APKWS spare parts; support equipment; missile software; training; 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 $100 million. The principal contractor will be BAE Systems, Inc., located in Falls Church, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/kingdom-saudi-arabia-advanced-precision-kill-weapon-systems

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DSCA Notifies Congress of Potential FMS Sale To Qatar

March 26, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Qatar has requested to buy eight (8) MQ-9B Remotely Piloted Aircraft (RPA); two hundred (200) KMU-572 Joint Direct Attack Munition (JDAM) tail kits for Guided Bomb Unit (GBU)-38 or Laser JDAM GBU-54; three hundred (300) BLU-111 500-lb general purpose bombs; one hundred (100) MXU-650 air foil groups (AFG) for Paveway II GBU-12; one hundred (100) MAU-169 computer control groups (CCG) for Paveway II GBU-12; twenty-eight (28) Embedded Global Positioning System (GPS)/Inertial Navigation System (INS) (EGI) security devices with M-Code; twelve (12) EGI security devices with Selective Availability Anti-Spoofing Modules (SAASM); ten (10) Lynx AN/APY-8 Synthetic Aperture Radars (SAR); ten (10) L3 Rio Grande communications intelligence (COMINT) sensor suites; one hundred ten (110) AGM-114R2 Hellfire II missiles; and eight (8) M36E9 Hellfire Captive Air Training Missiles (CATM). The following non-MDE items will also be included: Honeywell TPE-331 turboprop engines; Certifiable Ground Control Stations (CGCS); FMU-139D/B fuze systems; DSU-38 laser illuminated target detectors for GBU-54; KY-100M narrowband/wideband terminals; AN/PYQ-10 Simple Key Loaders (SKLs); Keying Identification Verification (KIV)-77 Mode 5 Identification Friend or Foe (IFF) cryptographic appliques; Intrusion Prevention System (IPS)-250X High Assurance Internet Protocol Encryptor (HAIPE) Type 1 cryptographic communications security (COMSEC) devices; Cryptographic Core Modernization (CCM)-700A Type 1 COMSEC chips; AN/DPX-7 IFF transponders; Link-16 KOR-24A Small Tactical Terminals (STTs); Semi-Automatic Ground Environment (SAGE) Electronic Surveillance Measure systems; AE-4500 Electronic Support Measure; Compact Multi-band Data Link (CMDL); Remotely Operated Video Enhanced Receiver (ROVER) 6Si compatible systems; Common Munitions Built-in-Test Reprogramming Equipment (CMBRE) Plus Block II; Mayflower Multi-Platform Anti-Jam GPS Navigation Antennas (MAGNA)-I, AS-4841; imaging systems; Electro-Optical/Infrared (EO/IR) Multi-Spectrum Targeting System (MTS); Active Electronically Scanned Array (AESA) radars (SeaSpray 7500 maritime radars); Due Regard Radar (DRR); Automatic Information System (AIS) transponders; Rohde & Schwartz Ultra High Frequency (UHF)/Very High Frequency (VHF) radios; satellite communications (SATCOM) ground station antennas, modems, and terminals with Unifi Security Gateway (USG) encryption; Ku-Band SATCOM GA-ASI Transportable Earth Stations (GATES); secure SATCOM systems; DSU-33D/B bomb components; M299 Longbow Hellfire launchers; weapons loading equipment; spare and repair parts, consumables and accessories, and repair and return support; weapons integration; support and test equipment; facilities and construction support; publications and technical documentation; personnel training and training equipment; transportation and airlift support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.96 billion. The principal contractors will be General Atomics Aeronautical Systems, located in Poway, CA; Lockheed Martin, located in Bethesda, MD; RTX Corporation, located in Waltham, MA; L3Harris, Inc., located in Melbourne, FL; Boeing Corporation, located in Arlington, VA; and Leonardo SpA, located in Rome, Italy. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/qatar-mq-9b-remotely-piloted-aircraft

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

SNAP-R has migrated to a new database. To access, you need to first migrate your old SNAP-R account.

Go to https://www.bis.gov/ and click on the Licensing subheading. Then click “Apply for licenses (SNAP-R).”

Then click “Migrate Legacy Account” and enter your SNAP-R login information.

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U.S. Census Bureau

Update to Automated Export System (AES)

March 5, 2025:

This message is a follow-up to the broadcast released on May 11, 2022, titled Expansion of Foreign Trade Zone Identifier to 9-characters (Effective May 17, 2022). The severity of Response Message 15A is being upgraded to “Compliance Alert” from “Informational” for a minimum of 120 days, and then will be upgraded to a severity of “Fatal” at a later date. This is to ensure further compliance with the changes outlined in Federal Register Notice 85 FR 60479 that requires the expansion of the Foreign Trade Zone Identifier from 7 to 9-characters.

Response Code: 15A

Narrative Text: FTZ MUST BE 9 CHARACTERS ALPHANUMERIC

Severity: COMPLIANCE ALERT

Reason: The Foreign Trade Zone Indicator reported on the SC2 record does not have the required format of 3 numeric characters which is a valid zone followed by 6 alphanumeric characters.

Resolution: The Foreign Trade Zone Indicator must be specified in the required format. The first 3 positions must be numeric and represent the general-purpose zone. The next 3 positions are alphanumeric and represent the subzone. The last 3 positions are alphanumeric and represent the site. The Foreign Trade Zone Indicator must be left justified with no trailing spaces. Insert zeros when there is no sub zone or site. Report leading zero(s) when the general-purpose zone is less than 3 numerics, and when the subzone or site is 1 alphanumeric. Verify the Foreign Trade Zone Indicator, correct the SC2 record and retransmit.

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Tips on How to Resolve AES Response Messages

March 24, 2025:

When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. Though the shipment is accepted, the filer may still receive a Verify Message, Compliance Alert, Informational Message or Warning Message along with their ITN. However, if the shipment is rejected, a Fatal Error notification is received and must be corrected to receive a valid ITN.

To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.

Response Code: 119

Narrative: Carrier Code Not Allowed for MOT

Severity: Fatal

Reason: A Carrier ID (SCAC/IATA) is reported but the Mode of Transportation Code indicates a carrier code is not allowed.

Resolution: A Carrier ID (SCAC/IATA) must be reported for Modes of Transportation vessel, air, rail and truck. A Carrier ID (SCAC/IATA) is not allowed to be reported for Modes of Transportation other than vessel, air, rail or truck (i.e., mail, fixed, etc.).

Verify the Mode of Transportation and the Carrier ID (SCAC/IATA), correct the shipment and resubmit.

Response Code: 331

Narrative: Ultimate Consignee Country Unknown

Severity: Fatal

Reason: The Ultimate Consignee Country code reported is not valid in AES.

Resolution: The Ultimate Consignee Country code must be a valid ISO Country code found in Appendix C – ISO Country Codes.

Verify the Ultimate Consignee Country code, correct the shipment and resubmit.

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Port of Unlading Codes Added in the Automated Export System (AES)

March 25, 2025:

Please note the following Port of Unlading Codes have been ADDED to the AES effective immediately.

Port Name Port Code Country

Fort Frances	09602	Canada
Puerto Madero	20192	Mexico
Alvarado	20196	Mexico

LATEST SANCTIONS FINES & PENALTIES

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

Fines and Penalties

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

March 18, 2025: The United States filed a civil forfeiture complaint in the Southern District of Florida against a Dassault Falcon 900 EX aircraft, bearing tail number T7-ESPRT, which was smuggled from the United States under false pretenses and operated for the benefit of Nicolás Maduro Moros (Maduro) and his representatives in the Bolivarian Republic of Venezuela (the Maduro Regime) in violation of U.S. sanctions and export control laws. The aircraft was seized last year in the Dominican Republic at the request of the United States.

This filing alleges that the Dassault Falcon 900 EX aircraft was purchased and maintained in violation of U.S. sanctions against Maduro and the Maduro Regime. According to the complaint, the aircraft is forfeitable based on violations of U.S. law, including the International Emergency Economic Powers Act (IEEPA) and money laundering violations.

https://www.justice.gov/opa/pr/us-files-civil-forfeiture-complaint-against-aircraft-used-nicolas-maduro-moros-violation-us

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March 26, 2025: An indictment was unsealed charging Mohammad Jawaid Aziz, also known as Jawaid Aziz Siddiqui and Jay Siddiqui, 67, of Pakistan and Canada, with conspiracy to violate U.S. export laws and violating U.S. export laws. Siddiqui was arrested on March 21 in the Western District of Washington while attempting to cross into the United States from Canada. He remains detained, pending transfer to the District of Minnesota.

As alleged, from as early as 2003 through approximately March 2019, Siddiqui operated an illicit procurement network through his Canada-based company Diversified Technology Services. The purpose of the network was to obtain U.S.-origin goods on behalf of prohibited entities in Pakistan that were associated with the country’s nuclear, missile, and Unmanned Aerial Vehicle (UAV) programs.

https://www.justice.gov/opa/pr/dual-pakistani-canadian-national-arrested-years-long-scheme-circumvent-us-export-control

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Sanctions

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

March 25, 2025: 90 Fed. Reg. 14046 and 90 Fed. Reg. 14032: The Department of Commerce’s Bureau of Industry and Security (BIS) added 80 entities to the Entity List from China, the United Arab Emirates (UAE), South Africa, Iran, Taiwan, and others for activities contrary to U.S. national security and foreign policy. As part of these measures, BIS is working toward the following objectives:

Restrict the Chinese Communist Party’s (CCP) ability to acquire and develop high-performance and exascale computing capabilities, as well as quantum technologies, for military applications;
Impede China’s development of its hypersonic weapons program;
Prevent entities associated with the Test Flying Academy of South Africa (TFASA) from using U.S. items to train Chinese military forces;
Disrupt Iran’s procurement of unmanned aerial vehicles (UAVs) and related defense items; and
Impair the development of unsafeguarded nuclear activities and ballistic missile program.

Specifically, these revisions to the Entity List include:

12 entities—11 under the destination of China and one under the destination of Taiwan—are added for engaging in the development of advanced AI, supercomputers, and high-performance AI chips for China-based end-users with close ties to the country’s military-industrial complex.
13 entities, including under the destinations of China, are added for their contributions to unsafeguarded nuclear activities.
7 entities are added for contributions to ballistic missile programs.
27 Chinese entities are added for acquiring or attempting to acquire U.S.-origin items in support of China’s military modernization. These entities have demonstrable ties to activities of concern, including the development of hypersonic weapons and the design and modeling of vehicles in hypersonic flight.
7 entities located in China are added for acquiring or attempting to acquire U.S.-origin items in support of advancing the CCP’s quantum technology capabilities, presenting serious ramifications for U.S. national security given the military applications of quantum technologies.
2 Chinese entities are being added for selling products to parties on the Entity List, including Huawei and affiliated entity HiSilicon.
2 entities in Iran and China are added for attempting to procure U.S.-origin items for Iran’s defense industry and unmanned aerial vehicle programs.
10 entities under the destinations of China, South Africa, and the UAE are added due to their links to the Test Flying Academy of South Africa (TFASA) —a party added to the Entity List on June 12, 2023—and the training of Chinese military forces using Western and NATO sources.

BIS also modified one existing entity, Dart Aviation, under four entries on the Entity List under the destinations of France, Iran, Senegal, and the United Kingdom. This entry is modified by adding two additional aliases and one additional address. Dart Aviation was added to the Entity List in 2019 for transshipping U.S.-origin items to sanctioned destinations.

These entities have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States:

China

Beijing Academy of Artificial Intelligence;
Beijing Innovation Wisdom Technology Co., Ltd.;
Henan Dingxin Information Industry Co., Ltd.;
Inspur (Beijing) Electronic Information Industry Co., Ltd.;
Inspur Electronic Information Industry Co., Ltd.;
Inspur Electronic Information (Hong Kong) Co., Ltd.;
Inspur (HK) Electronics Co., Ltd.;
Inspur Software Co., Ltd.;
Nettrix Information Industry Co., Ltd.;
Suma Techology Co., Ltd.;
Suma-USI Electronics Co., Ltd;
Aeronautics Computing Technique Research Institute;
Aerospace Star Technology Application Co., Ltd.;
Air Force Engineering University;
Anhui Kehua Sci-Tech Trading Co., Ltd.;
Associated Opto-electronics (Chongqing) Co., Ltd.;
Beijing Foundfresh Technology Co., Ltd.;
Beijing Graphene Institute Co., Ltd;
Beijing Guoke Tianxun Technology Co., Ltd.;
Chengdu Aircraft Design and Research Institute;
China Academy of Launch Vehicle Technology Beijing Institute of Precision Mechatronics Control Equipment;
China Aeronautical Radio Electronics Research Institute;
Chinese Academy of Sciences Technology and Engineering Center for Space Utilization;
Chongqing Southwest Integrated Circuit Design Co., Ltd.;
Gyro Technology Co., Ltd.;
Harbin Aerospace Star Data System Technology Co., Ltd.;
Jiangxi Hongdu Aviation Industry Group Co., Ltd.;
Mohammad Reza Rajabi;
Nanjing Chunhui Technology Industry Co., Ltd.;
Nanjing Fiberglass Research and Design Institute;
Nanjing Panda Handa Technology Co., Ltd.;
National Inspection and Testing Holding Group Nanjing National Materials Testing Co., Ltd.;
Ningbo Institute of Materials Technology and Engineering;
ORICAS Import and Export (Beijing) Corporation;
Physike Technology Co., Ltd.;
Scikro (Hong Kong) Instruments Limited;
Scikro (Shanghai) Instrument Co., Ltd.;
Shaanxi Aerospace Science and Technology Co., Ltd.;
Shanghai Aviation Electronic Co., Ltd.;
Silk Road Trading Company Ltd.;
Singleton (Suzhou) Electronics Technology Co., Ltd.;
Space Star Technology Co., Ltd.;
Stratum FT Limited;
Suzhou Changfeng Avionics Co., Ltd.;
Suzhou SIP Hi-Tech Precision Electronics Co., Ltd.;
Tianjin Aerospace Zhongwei Data System Technology Co., Ltd.;
Xi'an Aerospace Automation Co., Ltd.;
Xi'an Aerospace Tianhui Data Technology Co., Ltd.;
Xi'an Sunward Aeromat Co., Ltd.;
Xi'an Xiangteng Microelectronics Technology Co., Ltd.;
Xi'an Xiangxun Technology Co., Ltd.;
Zhejiang Aerospace Hengjia Data Technology Co., Ltd.; and
Zibo Topred International Trading Company Limited.

Taiwan

Inspur Taiwan.

Iran

Mohammad Reza Rajabi; and
Silk Road Trading Company Ltd.

Pakistan

Allied Business Concerns (Pvt) Ltd;
Ariston Trade Links;
Britlite Engineering Company;
Global Traders;
Indentech International;
IntraLink Incorporated;
Linkers Automation (Pvt) Ltd;
NA Enterprises;
Otto Manufacturing;
Potohar Industrial & Trading Concern;
Proc-Master;
Professional Systems (Pvt) Ltd.;
Rachna Supplies (Pvt) Ltd;
RASTEK Technologies;
Rehman Engineering and Services;
Resource Enterprises;
Sine Technologies;
Supply Source Co.; and
The Sadidians.

South Africa

Ascenso Aviation;
Blue Sky Aviation (Pty) Ltd.; and
Wingman Concept (Pty) Ltd.

United Arab Emirates

Astec Astronomy FZCO;
Roche Consulting Limited;
TFASA Helicopter International; and
TG Training 2023 FZCO.

https://www.bis.gov/press-release/commerce-further-restricts-chinas-artificial-intelligence-advanced-computing-capabilities

https://www.federalregister.gov/documents/2025/03/28/2025-05427/additions-to-the-entity-list and

https://www.federalregister.gov/documents/2025/03/28/2025-05426/additions-and-modifications-to-the-entity-list

*******

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

March 2, 2025: OFAC has published a frequently asked question (FAQ 1218) regarding the President's February 26 announcement on energy-related authorizations in Venezuela.

FAQ 1218:

Q: How is Treasury planning to implement the President’s February 26 announcement on energy-related authorizations in Venezuela?

A: Treasury is preparing to take action to wind-down General License 41 and other specific licenses as appropriate. We will issue additional guidance to assist implementation concurrent with any changes to the authorization(s).

https://ofac.treasury.gov/faqs/1218 and

https://ofac.treasury.gov/recent-actions/20250302

*******

March 4, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Iran-based Behrouz Parsarad (Parsarad), the sole administrator of Nemesis, an online darknet marketplace, which was subject of an international law enforcement operation and was taken down in 2024. Prior to its takedown by law enforcement, narcotics traffickers and cybercriminals openly traded in illegal drugs and services on Nemesis, which was designed with built-in money laundering features. Nemesis had over 30,000 active users and 1,000 vendors and facilitated the sale of nearly $30 million worth of drugs around the world between 2021 and 2024, including to the United States. These sanctions designation is OFAC’s first action as a member of the Federal Bureau of Investigation (FBI)-led interagency Joint Criminal Opioid and Darknet Enforcement (JCODE) Team.

The following individual has been added to OFAC’s SDN List:

Parsarad, Behrouz of Iran.

https://home.treasury.gov/news/press-releases/sb0040

https://ofac.treasury.gov/media/934026/download?inline

*******

March 4, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Venezuela General License 41A, "Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation's Joint Ventures in Venezuela."

GENERAL LICENSE NO. 41A: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela”

(a) All transactions ordinarily incident and necessary to the wind down of transactions previously authorized by Venezuela General License 41 related to the operation and management by Chevron Corporation or its subsidiaries (“Chevron”) of Chevron’s joint ventures in Venezuela (collectively, the “Chevron JVs”) involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, that are prohibited by Executive Order (E.O.) 13850, as amended by E.O. 13857, or E.O. 13884, each as incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized through 12:01 a.m. eastern daylight time, April 3, 2025.

https://ofac.treasury.gov/recent-actions/20250304

*******

March 5, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against seven high-ranking members of Ansarallah, commonly known as the Houthis. These individuals have smuggled military-grade items and weapon systems into Houthi-controlled areas of Yemen and also negotiated Houthi weapons procurements from Russia. OFAC also designated one Houthi-affiliated operative and his company that have recruited Yemeni civilians to fight on behalf of Russia in Ukraine and generated revenue to support the Houthis’ militant operations.

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

Abdulsalam, Mohammad of Yemen;
Alagri, Abdulmalek Abdullah Mohammed of Yemen;
Al-Hadi, Ali Muhammad Muhsin Salih of Yemen;
Al-Houthi, Mohamed Ali of Yemen;
Al-Jabri, Abdulwali Abdoh Hasan of Yemen;
Almarwani, Eshaq Abdulmalek Abdullah of Yemen;
Al-Mashat, Mahdi Mohammed Hussein of Yemen; and
Gaber, Khaled Hussein Saleh of Yemen.

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

Al-Jabri General Trading and Investment Co

https://ofac.treasury.gov/recent-actions/20250305 and

https://home.treasury.gov/news/press-releases/sb0041

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March 5, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Zhou Shuai, a Shanghai-based malicious cyber actor and data broker, and his company, Shanghai Heiying Information Technology Company, Limited (Shanghai Heiying). In collaboration with another malicious cyber actor, U.S.-sanctioned Yin Kecheng, Zhou Shuai illegally acquired, brokered, and sold data from highly sensitive U.S. critical infrastructure networks. Malicious cyber actors, particularly those operating in China, continue to be one of the greatest and most persistent threats to U.S. national security, as highlighted in the Office of the Director of National Intelligence’s most recent Annual Threat Assessment.

The following individual has been added to OFAC’s SDN List:

Zhou, Shuai of China.

The following entity has been added to OFAC’s SND List:

Shanghai Heiying Information Technology Company Limited of China.

https://ofac.treasury.gov/recent-actions/20250305 and

https://home.treasury.gov/news/press-releases/sb0042

*******

March 5, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Counter Terrorism General License 22A, "Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates Involving Ansarallah"; Counter Terrorism General License 23A, "Authorizing Transactions Related to Telecommunications, Mail, and Certain Internet-Based Communications Involving Ansarallah"; Counter Terrorism General License 24A, "Authorizing Noncommercial, Personal Remittances Involving Ansarallah"; Counter Terrorism General License 25A, "Authorizing the Offloading of Refined Petroleum Products in Yemen Involving Ansarallah"; Counter Terrorism General License 26A, "Authorizing Certain Transactions Necessary to Port and Airport Operations Involving Ansarallah"; and Counter Terrorism General License 28A, "Authorizing Transactions for Third-Country Diplomatic and Consular Missions Involving Ansarallah".

GENERAL LICENSE NO. 22A: “Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates Involving Ansarallah”

(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the provision (including sale) of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Yemen, or to persons in third countries purchasing specifically for provision to Yemen, are authorized.

(b) For the purposes of this general license, agricultural commodities, medicine, and medical devices are defined as follows:

(1) Agricultural commodities. Agricultural commodities are products that:

(i) Fall within the term “agricultural commodity” as defined in section 102 of the Agricultural Trade Act of 1978 (7 U.S.C. 5602); and

(ii) Are intended for ultimate use in Yemen as:

(A) Food for humans (including raw, processed, and packaged foods; live animals; vitamins and minerals; food additives or supplements; and bottled drinking water) or animals (including animal feeds);

(B) Seeds for food crops;

(D) Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food animals.

(2) Medicine. Medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).

(3) Medical devices. A medical device is an item that falls within the definition of “device” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).

GENERAL LICENSE NO. 23A: “Authorizing Transactions Related to Telecommunications, Mail, and Certain Internet Based Communications Involving Ansarallah”

(a)(1) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, with respect to the receipt or transmission of telecommunications within Yemen are authorized.

(b) The exportation, reexportation, or provision, directly or indirectly, from the United States or by U.S. persons, wherever located, to Yemen, of services, software, hardware, or technology incident to the exchange of communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, voice over internet protocol (VOIP), e-gaming, elearning platforms, automated translation, web maps, and user authentication services, as well as cloud-based services in support of the foregoing, and domain name registration services, involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that is prohibited by the GTSR or FTOSR, is authorized, provided the exportation, reexportation, or provision is not to a person whose property and interests in property are blocked pursuant to the GTSR or FTOSR.

(c) All transactions of common carriers incident to the receipt or transmission of mail and packages between the United States and Yemen, or within Yemen, involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are prohibited by the GTSR or the FTOSR are authorized, provided that the importation or exportation of such mail and packages is not to or from any person blocked pursuant to the GTSR or the FTOSR.

GENERAL LICENSE NO. 24A: “Authorizing Noncommercial, Personal Remittances Involving Ansarallah”

(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances to or from an individual in Yemen, are authorized, provided the individual is not a person whose property or interests in property are blocked pursuant to the GTSR or the FTOSR.

Note to paragraph (a). Noncommercial, personal remittances do not include charitable donations of funds to or for the benefit of an entity or funds transfers for use in supporting or operating a business, including a family-owned business.

(b) Transferring institutions may rely on the originator of a funds transfer with regard to compliance with paragraph (a) of this general license, provided that the transferring institution does not know or have reason to know that the funds transfer is not in compliance with paragraph (a).

GENERAL LICENSE NO. 25A: “Authorizing the Offloading of Refined Petroleum Products in Yemen Involving Ansarallah”

(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the delivery and offloading of refined petroleum products for personal, commercial, or humanitarian use in Yemen are authorized, through 12:01 a.m. eastern daylight time, April 4, 2025, provided the refined petroleum products were loaded on a vessel prior to March 5, 2025

GENERAL LICENSE NO. 26A: “Authorizing Certain Transactions Necessary to Port and Airport Operations Involving Ansarallah”

(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the operation of, or import or export of goods or transit of passengers through, ports and airports in Yemen are authorized.

GENERAL LICENSE NO. 28A: “Authorizing Transactions for Third-Country Diplomatic and Consular Missions Involving Ansarallah”

(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the official business of third-country diplomatic or consular missions to Yemen are authorized.

Additionally, OFAC has issued a new Counter Terrorism Frequently Asked Question (FAQ 1219).

FAQ 1219:

Q: On March 4, 2025, the Department of State (State) designated Ansarallah as a Foreign Terrorist Organization (FTO). What actions did OFAC take related to this announcement?

A: OFAC implemented State's designation of Ansarallah ("the Houthis") as an FTO by updating the existing Ansarallah entry on the Specially Designated Nationals and Blocked Persons List (SDN List). Ansarallah was already listed on the SDN List as a result of State's February 16, 2024 designation of the group as a Specially Designated Global Terrorist (SDGT).

OFAC also updated three Ansarallah-related general licenses (GLs) to authorize certain transactions under the Foreign Terrorist Organizations Sanctions Regulations (FTOSR) (31 C.F.R. part 597): agricultural commodities, medicine, and medical devices (GL 22A); noncommercial, personal remittances (GL 24A); and third-country diplomatic missions (GL 28A).

OFAC also amended three additional Ansarallah-related GLs. Specifically, OFAC issued GL 25A, which winds down the previously issued GL by authorizing the delivery and offloading of refined petroleum products in Yemen through 12:01 a.m. eastern daylight time April 4, 2025, provided such products were loaded on a vessel prior to March 5, 2025. Authorizations in GL 25A replace and supersede previous authorization for transactions related to the provision of refined petroleum products in GL 25. Additionally, OFAC issued GL 26A to exclude refined petroleum products from goods that can be imported or exported through ports and airports in Yemen. OFAC also issued GL 23A, which eliminates the previous authorization of transactions for the receipt or transmission of telecommunications to or from Yemen and now only authorizes transactions within Yemen for the receipt or transmission of telecommunications involving Ansarallah.

The above GLs supplement broad preexisting humanitarian GLs in the Global Terrorism Sanctions Regulations (GTSR) and FTOSR covering the United States government, certain international organizations and entities, nongovernmental organizations (NGOs), and for the provision of food, other agricultural commodities, medicine, and medical devices for personal, non-commercial use. For more information on these baseline humanitarian general licenses, please consult OFAC's Supplemental Guidance for the Provision of Humanitarian Assistance, and FAQs 1105, 1106, 1107, and 1108. Other humanitarian-related guidance documents are available in the NGO section of OFAC's Information for Industry Groups webpage. Note that activities authorized by GLs issued by OFAC do not relieve persons from compliance with any other laws or requirements of other federal agencies.

As a result of OFAC's amendments to Ansarallah-related GLs in conjunction with the FTO designation, OFAC has also removed OFAC's Compliance Communiqué: Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People.

Non-U.S. persons may engage in or facilitate transactions for which a U.S. person would not require a specific license pursuant to the GTSR or FTOSR without exposure to sanctions under the GTSR or FTOSR.

OFAC prioritizes specific license applications and requests for guidance related to humanitarian activity. OFAC encourages anyone with questions to reach out to the OFAC Compliance Hotline.

https://ofac.treasury.gov/recent-actions/20250305

https://ofac.treasury.gov/media/934031/download?inline

https://ofac.treasury.gov/media/934036/download?inline

https://ofac.treasury.gov/media/934041/download?inline

https://ofac.treasury.gov/media/934046/download?inline

https://ofac.treasury.gov/media/934051/download?inline

https://ofac.treasury.gov/media/934056/download?inline

https://ofac.treasury.gov/faqs/1219

*******

March 13, 2025: The Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Foxtrot Network, a transnational criminal organization (TCO) primarily based in Sweden that has trafficked illicit drugs and that carried out attacks on Israelis and Jews in Europe, along with its fugitive leader Rawa Majid. In January 2024, the Foxtrot Network orchestrated an attack on the Israeli Embassy in Stockholm, Sweden, on behalf of the Government of Iran.

The following individual has been added to OFAC’s SDN List:

Majid, Rawa of Iran.

The following entity has been added to OFAC’s SDN List:

Foxtrot Network of Sweden.

https://ofac.treasury.gov/recent-actions/20250312

https://home.treasury.gov/news/press-releases/sb0047

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March 13, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Iran’s Minister of Petroleum, Mohsen Paknejad, who oversees the export of tens of billions of dollars’ worth of Iranian oil and has allocated billions of dollars’ worth of oil to Iran’s armed forces for export. OFAC also designated several entities in multiple jurisdictions, including the People’s Republic of China (PRC) and India, for their ownership or operation of vessels that have delivered Iranian oil to the PRC, or lifted Iranian oil from storage in Dalian, PRC. These sanctions apply further pressure on the “shadow fleet” and other vessels upon which Iran depends to deliver its oil to the PRC, advancing United States’ commitment to reduce Iran’s oil exports to zero.

The following individual has been added to OFAC’s SDN List:

Pankejad, Mohsen of Iran.

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

Aren Ship Management of Bangladesh;
Celestite Maritime Inc of the Marshall Islands;
Fallon Shipping Company Limited of Seychelles;
Hong Kong Heshun Transportation Trading Limited of China;
Huaxia Trading Ltd of China;
Itaugua Services Inc of Liberia;
Lake View Ship Management Private Limited of India;
Marine Solution PVT Ltd of Sri Lanka;
Neptune Marine Ltd of the Marshall Islands;
Bintang Samudra Utama of Indonesia;
Gianira Adhinusa Senatama of Indonesia;
Sea Services Providers NV of Suriname;
Seasky Marine Co., Limited of China;
Shipload Maritime PTE. LTD of Singapore;
Sun Science International Co., Limited of China;
Turquoise Sea Marine Limited of Seychelles; and
United Tankers LTD of the Marshall Islands.

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

Blue Gulf (T8A4799) Crude Oil Tanker Palau flag; MMSI 511101436 (vessel);
Celebes (YDA3301) Tug Indonesia flag; MMSI 525018077 (vessel);
Corona Fun (3E5355) Crude Oil Tanker Panama flag; MMSI 352003958 (vessel);
Itaugua (D6A3529) Crude Oil Tanker Comoros flag; MMSI 620999528 (vessel);
Lexi (TJ04M) Crude Oil Tanker Cameroon flag; MMSI 613806561 (vessel);
Lyda N (T8A4077) Crude Oil Tanker Palau flag; MMSI 511100863 (vessel);
Malili (YBEN) Tug Indonesia flag; MMSI 525018442 (vessel);
Marina Vision (YDA3415) Tug Indonesia flag; MMSI 525010379 (vessel);
Neso (3E5143) Crude Oil Tanker PANAMA flag; MMSI 352003483 (vessel);
Peace Hill (VRGO9) Crude Oil Tanker Hong Kong flag; MMSI 477738400 (vessel);
Polaris 1(EPXT5) Chemical/Oil Tanker Iran flag; MMSI 422546600 (vessel);
Seasky (T7BN2) Crude Oil Tanker San Marino flag; MMSI 268242902 (vessel); and
SHANNON II (8P2369) Crude Oil Tanker Barbados flag; MMSI 314903000 (vessel).

https://home.treasury.gov/news/press-releases/sb0049

https://ofac.treasury.gov/recent-actions/20250313

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March 18, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Jumilca Sandivel Hernandez Perez (Hernandez Perez), a key leader of the Lopez Human Smuggling Organization (HSO), a Guatemala-based Transnational Criminal Organization responsible for the smuggling of thousands of illegal aliens from Guatemala, through Mexico, and into the United States. Additionally, Hernandez Perez has coordinated her illegal activity with members of the violent U.S.-sanctioned drug trafficking organization, La Linea, which among other heinous acts is responsible for the November 2019 murders of nine American citizens, including six children, in the Mexican state of Sonora.

OFAC published a new Counter Terrorism-related OFAC Alert, "International Cartels Designated as Foreign Terrorist Organizations and Specially Designated Global Terrorists."

The following individual has been added to OFAC’s SDN List:

Hernandez, Perez of Mexico.

https://home.treasury.gov/news/press-releases/sb0051 and

https://ofac.treasury.gov/media/934096/download?inline

https://ofac.treasury.gov/recent-actions/20250318

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March 20, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a “teapot” oil refinery and its chief executive officer for purchasing and refining hundreds of millions of dollars’ worth of Iranian crude oil, including from vessels linked to the Foreign Terrorist Organization, Ansarallah, commonly known as the Houthis, and the Iranian Ministry of Defense of Armed Forces Logistics (MODAFL).

The Department of the Treasury's Office of Foreign Assets Control (OFAC) published the Final Rule to Extend Recordkeeping Requirements from Five to 10 Years, consistent with the extension of the statute of limitations for violations of certain sanctions administered by OFAC.

The following individual has been added to OFAC’s SDN List:

Wang, Xueqing of China.

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

Astrid Menks Limited of China;
Britney Ryder Limited of China;
Canes Ventici Limited of China;
Citywallship Management Co Ltd of China;
Huaying Huizhou Daya Vay Petrochemical Terminal Storage Co. Ltd of China;
Jetee Co., Limited of China;
Lyrari Group Ltd of Virgin Islands;
Placencia Services Incorporation of Liberia;
Sea Breeze Shipping Inc of Panama;
Seapalm Shipping Limited of Seychelles;
Setasean Ship Management Limited of China;
Shandong Shouguang Luqing Petrochemical Co., Ltd. of China; and
Zenith Bridge Inc of Panama.

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

Aurora Riley (HPKT) Crude Oil Tanker Panama flag; MMSI 356024000 (vessel);
Brava Lake (8P2225) Crude Oil Tanker Barbados flag; MMSI 314867000 (vessel);
Catalina 7 (3E4129) Crude Oil Tanker Panama flag; MMSI 352001485 (vessel);
Montrose (T7BJ4) Crude Oil Tanker San Marino flag; MMSI 268240502 (vessel);
Natalina 7 D6A3622) Crude Oil Tanker Comoros flag; MMSI 620999608 (vessel);
Titan (TJ03M) Crude Oil Tanker Unknown flag; IMO 9293741 (vessel);
Viola (3EHD8) Crude Oil Tanker Panama flag; MMSI 354951000 (vessel); and
Volans (8PDO3) Crude Oil Tanker Barbados flag; MMSI 314679000 (vessel).

https://ofac.treasury.gov/recent-actions/20250320

https://home.treasury.gov/news/press-releases/sb0056

https://ofac.treasury.gov/media/934131/download?inline

*******

March 24, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela General License 41B, "Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation's Joint Ventures in Venezuela."

GENERAL LICENSE NO. 41B: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela”

(a) All transactions ordinarily incident and necessary to the wind down of transactions previously authorized by Venezuela General License 41, issued on November 26, 2022, related to the operation and management by Chevron Corporation or its subsidiaries (“Chevron”) of Chevron’s joint ventures in Venezuela (collectively, the “Chevron JVs”) involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, that are prohibited by Executive Order (E.O.) 13850, as amended by E.O. 13857, or E.O. 13884, each as incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized through 12:01 a.m. eastern daylight time, May 27, 2025.

https://ofac.treasury.gov/media/934071/download?inline

*******

March 25, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the Federal Bureau of Investigation (FBI), imposed sanctions on three Iranian Ministry of Intelligence and Security (MOIS) officials who were involved in the abduction, detention, and probable death of former FBI Special Agent Robert A. “Bob” Levinson. The individuals designated, Reza Amiri Moghadam, Gholamhossein Mohammadnia, and Taqi Daneshvar, all played a role in Mr. Levinson’s abduction, probable death, and Iran’s efforts to cover up or obfuscate their responsibility. This action follows the December 2020 OFAC designations of two Iranian MOIS officers, Mohammad Baseri and Ahmad Khazai, who acted in their capacity as MOIS officers in Mr. Levinson’s abduction, detention, and probable death.

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

Daneshvar, Taqi of Iran;
Moghadam, Reza Amiri of Iran; and
Mohammadnia, Gholamhossein of Iran.

https://home.treasury.gov/news/press-releases/sb0059 and

https://ofac.treasury.gov/recent-actions/20250325

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March 28, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated five individuals, and three associated companies involved in a Lebanon-based sanctions evasion network supporting the Hizballah finance team. The Hizballah finance team manages a variety of lucrative commercial projects and oil smuggling networks, often in conjunction with Iran’s Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF), to generate and transfer revenue for Hizballah. The Hizballah finance team uses front companies to generate millions of dollars in revenue for Hizballah and support the group’s terrorist activities, while also allowing key associates and family members, like those designated, to enrich themselves through these commercial enterprises.

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

Al-Bazzal, Rashid Qasim of Lebanon;
Ayyub, Fatimah ‘Abdallah of Lebanon;
Ayyub, Hawra’ ‘Abdallah of Turkey;
Khafaja, Jamil Mohamad of Lebanon; and
Murtada, Mahasin Mahmud of Turkey.

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

Lebanese United Group SAL of Lebanon;
Ravee Sarl of Lebanon; and
Securol Glass Curtains of Lebanon.

https://ofac.treasury.gov/recent-actions/20250328 and

https://home.treasury.gov/news/press-releases/sb0063

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March 31, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and seven entities involved in a money laundering network supporting the Sinaloa Cartel, one of the most notorious and violent drug trafficking organizations in the world, and a U.S.-designated Foreign Terrorist Organization (FTO). The Sinaloa Cartel is responsible for a significant portion of the illicit fentanyl and other deadly drugs trafficked into the United States and has exploited multiple ports of entry along the southern border for its criminal activities. This action is the culmination of a coordinated investigation by the U.S. Attorney’s Office for the Southern District of California, the Drug Enforcement Administration, the Federal Bureau of Investigation, Internal Revenue Service – Criminal Investigations, Homeland Security Investigations, and the Government of Mexico, including the Unidad de Inteligencia Financiera, Mexico’s Financial Intelligence Unit.

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

Amador Valenzuela, Christian Noe of Mexico;
Benguiat Jimenez, Alberto David of Mexico City;
Diaz Rodriguez, Salvador of Mexico;
Esparragoza Rosas, Enrique Dann of Mexico;
Paez Vargas, Israel Daniel of Mexico; and
Viramontes Sesteaga, Alan of Mexico.

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

Grupo Unter Empresarial S.A. DE C.V. of Mexico;
Grupo Vindende S.A. DE C.V. of Mexico;
Grupo Zipfel De Mexico S.A. DE C.V. of Mexico;
Personas Unidas Hoas, S.A.P.I DE C.V. of Mexico;
Productions Pipos S. DE. R.L. DE C.V. of Mexico;
Scatman and Hatman Corp, S.A.P.I. DE C.V. of Mexico; and
Tapagas Mexico S.A. DE C.V. of Mexico.

https://ofac.treasury.gov/recent-actions/20250331 and

https://ofac.treasury.gov/recent-actions/20250331

MARCH 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

JANUARY 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES

LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE

January 2025

This newsletter is a listing of the latest changes in export control regulations through January 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

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

REGULATORY UPDATES

President

President Trump Announces America First Trade Policy

January 20, 2025: In 2017, President Trump’s Administration pursued trade and economic policies that put the American economy, the American worker, and our national security first. President Trump will established a robust and reinvigorated trade policy that promotes investment and productivity, enhances the Nation’s industrial and technological advantages, defends the economic and national security, and — above all — benefits American workers, manufacturers, farmers, ranchers, entrepreneurs, and businesses.

Addressing Unfair and Unbalanced Trade. The Secretary of Commerce, in consultation with the Secretary of the Treasury and the United States Trade Representative, shall investigate the causes of the country’s large and persistent annual trade deficits in goods, as well as the economic and national security implications and risks resulting from such deficits, and recommend appropriate measures, such as a global supplemental tariff or other policies, to remedy such deficits.

The Secretary of the Treasury, in consultation with the Secretary of Commerce and the Secretary of Homeland Security, shall investigate the feasibility of establishing and recommend the best methods for designing, building, and implementing an External Revenue Service (ERS) to collect tariffs, duties, and other foreign trade-related revenues.

The United States Trade Representative, in consultation with the Secretary of the Treasury, the Secretary of Commerce, and the Senior Counselor for Trade and Manufacturing, shall undertake a review of, and identify, any unfair trade practices by other countries and recommend appropriate actions to remedy such practices under applicable authorities, including, but not limited to, the Constitution of the United States; sections 71 through 75 of title 15, United States Code; sections 1337, 1338, 2252, 2253, and 2411 of title 19, United States Code; section 1701 of title 50, United States Code; and trade agreement implementing acts.

The United States Trade Representative shall commence the public consultation process set out in section 4611(b) of title 19, United States Code, with respect to the United States-Mexico-Canada Agreement (USMCA) in preparation for the July 2026 review of the USMCA. Additionally, the United States Trade Representative, in consultation with the heads of other relevant executive departments and agencies, shall assess the impact of the USMCA on American workers, farmers, ranchers, service providers, and other businesses and make recommendations regarding the United States’ participation in the agreement. The United States Trade Representative shall also report to appropriate congressional committees on the operation of the USMCA and related matters consistent with section 4611(b) of title 19, United States Code.

The Secretary of the Treasury shall review and assess the policies and practices of major United States trading partners with respect to the rate of exchange between their currencies and the United States dollar pursuant to section 4421 of title 19, United States Code, and section 5305 of title 22, United States Code. The Secretary of the Treasury shall recommend appropriate measures to counter currency manipulation or misalignment that prevents effective balance of payments adjustments or that provides trading partners with an unfair competitive advantage in international trade, and shall identify any countries that he believes should be designated as currency manipulators.

The United States Trade Representative shall review existing United States trade agreements and sectoral trade agreements and recommend any revisions that may be necessary or appropriate to achieve or maintain the general level of reciprocal and mutually advantageous concessions with respect to free trade agreement partner countries.

The United States Trade Representative shall identify countries with which the United States can negotiate agreements on a bilateral or sector-specific basis to obtain export market access for American workers, farmers, ranchers, service providers, and other businesses and shall make recommendations regarding such potential agreements.

The Secretary of Commerce shall review policies and regulations regarding the application of antidumping and countervailing duty (AD/CVD) laws, including with regard to transnational subsidies, cost adjustments, affiliations, and “zeroing.” Further, the Secretary of Commerce shall review procedures for conducting verifications pursuant to section 1677 of title 19, United States Code, and assess whether these procedures sufficiently induce compliance by foreign respondents and governments involved in AD/CVD proceedings. The Secretary of Commerce shall consider modifications to these procedures, as appropriate.

The Secretary of the Treasury, the Secretary of Commerce, the Secretary of Homeland Security, and the Senior Counselor for Trade and Manufacturing, in consultation with the United States Trade Representative, shall assess the loss of tariff revenues and the risks from importing counterfeit products and contraband drugs, e.g., fentanyl, that each result from the current implementation of the $800 or less, duty-free de minimis exemption under section 1321 of title 19, United States Code, and shall recommend modifications as warranted to protect both the revenue of the United States and the public health by preventing unlawful importations.

The Secretary of the Treasury, in consultation with the Secretary of Commerce and the United States Trade Representative, shall investigate whether any foreign country subjects United States citizens or corporations to discriminatory or extraterritorial taxes pursuant to section 891 of title 26, United States Code.

The United States Trade Representative, in consultation with the Senior Counselor for Trade and Manufacturing, shall review the impact of all trade agreements — including the World Trade Organization Agreement on Government Procurement — on the volume of Federal procurement covered by Executive Order 13788 of April 18, 2017 (Buy American and Hire American), and shall make recommendations to ensure that such agreements are being implemented in a manner that favors domestic workers and manufacturers, not foreign nations.

Economic and Trade Relations with the People’s Republic of China (PRC). The United States Trade Representative shall review the Economic and Trade Agreement Between the Government of the United States of America and the Government of the People’s Republic of China to determine whether the PRC is acting in accordance with this agreement, and shall recommend appropriate actions to be taken based upon the findings of this review, up to and including the imposition of tariffs or other measures as needed.

The United States Trade Representative shall assess the May 14, 2024, report entitled “Four-Year Review of Actions Taken in the Section 301 Investigation: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation” and consider potential additional tariff modifications as needed under section 2411 of title 19, United States Code — particularly with respect to industrial supply chains and circumvention through third countries, including an updated estimate of the costs imposed by any unfair trade practices identified in such review — and he shall recommend such actions as are necessary to remediate any issues identified in connection with this process.

The United States Trade Representative shall investigate other acts, policies, and practices by the PRC that may be unreasonable or discriminatory and that may burden or restrict United States commerce, and shall make recommendations regarding appropriate responsive actions, including, but not limited to, actions authorized by section 2411 of title 19, United States Code.

The Secretary of Commerce and the United States Trade Representative shall assess legislative proposals regarding Permanent Normal Trade Relations with the PRC and make recommendations regarding any proposed changes to such legislative proposals.

The Secretary of Commerce shall assess the status of United States intellectual property rights such as patents, copyrights, and trademarks conferred upon PRC persons, and shall make recommendations to ensure reciprocal and balanced treatment of intellectual property rights with the PRC.

Additional Economic Security Matters. The Secretary of Commerce, in consultation with the Secretary of Defense and the heads of any other relevant agencies, shall conduct a full economic and security review of the United States’ industrial and manufacturing base to assess whether it is necessary to initiate investigations to adjust imports that threaten the national security of the United States under section 1862 of title 19, United States Code.

The Assistant to the President for Economic Policy, in consultation with the Secretary of Commerce, the United States Trade Representative, and the Senior Counselor for Trade and Manufacturing, shall review and assess the effectiveness of the exclusions, exemptions, and other import adjustment measures on steel and aluminum under section 1862 of title 19, United States Code, in responding to threats to the national security of the United States, and shall make recommendations based upon the findings of this review.

The Secretary of State and the Secretary of Commerce, in cooperation with the heads of other agencies with export control authorities, shall review the United States export control system and advise on modifications in light of developments involving strategic adversaries or geopolitical rivals as well as all other relevant national security and global considerations. Specifically, the Secretary of State and the Secretary of Commerce shall assess and make recommendations regarding how to maintain, obtain, and enhance our Nation’s technological edge and how to identify and eliminate loopholes in existing export controls -– especially those that enable the transfer of strategic goods, software, services, and technology to countries to strategic rivals and their proxies. In addition, they shall assess and make recommendations regarding export control enforcement policies and practices, and enforcement mechanisms to incentivize compliance by foreign countries, including appropriate trade and national security measures.

The Secretary of Commerce shall review and recommend appropriate action with respect to the rulemaking by the Office of Information and Communication Technology and Services (ICTS) on connected vehicles, and shall consider whether controls on ICTS transactions should be expanded to account for additional connected products.

The Secretary of the Treasury, in consultation with the Secretary of Commerce and, as appropriate, the heads of any other relevant agencies, shall review whether Executive Order 14105 of August 9, 2023 (Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern) should be modified or rescinded and replaced, and assess whether the final rule entitled “Provisions Pertaining to U.S. Investments in Certain National Security Technologies and Products in Countries of Concern,” 89 Fed. Reg. 90398 (November 15, 2024), which implements Executive Order 14105, includes sufficient controls to address national security threats. The Secretary of the Treasury shall make recommendations based upon the findings of this review, including potential modifications to the Outbound Investment Security Program.

The Director of the Office of Management and Budget shall assess any distorting impact of foreign government financial contributions or subsidies on United States Federal procurement programs and propose guidance, regulations, or legislation to combat such distortion.

The Secretary of Commerce and the Secretary of Homeland Security shall assess the unlawful migration and fentanyl flows from Canada, Mexico, the PRC, and any other relevant jurisdictions and recommend appropriate trade and national security measures to resolve that emergency.

Reports. The results of the reviews and investigations, findings, identifications, and recommendations identified above.

Nothing in this memorandum shall be construed to impair or otherwise affect:

(i) the authority granted by law to an executive department or agency, or the head thereof; or

(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.

(b) This memorandum shall be implemented consistent with applicable law and subject to the availability of appropriations.

(c) This memorandum is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

https://www.whitehouse.gov/presidential-actions/2025/01/america-first-trade-policy/

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

Department of State 2025 Civil Monetary Penalties Inflationary Adjustment and New Maximum Penalty for Violation of Section 38 of the AECA

January 10, 2025: 90 Fed. Reg. 1866: On January 10, 2025, the Department of State published a final rule to adjust the civil monetary penalties at section 127.10 of the International Traffic in Arms Regulations (ITAR) as part of a larger rule amending penalties for all regulatory provisions maintained and enforced by the Department of State. ITAR section 127.10(a)(1)(i) through (iii) providing maximum penalties under sections 38 (22 U.S.C. 2778), 39A (22 U.S.C. 2779a), and 40 (22 U.S.C. 2780) of the AECA, respectively, are adjusted for inflation in accordance with the December 2024 guidance from the Office of Management and Budget (OMB M-25-02). The revised amounts for violations of those sections will apply to those penalties assessed on or after January 10, 2025, regardless of the date on which the underlying facts or violations occurred.

The Assistant Secretary of State for Political-Military Affairs is authorized to impose a civil penalty, as follows:

(i) For each violation of 22 U.S.C. 2778, an amount not to exceed the greater of $1,271,078 (from $1,238,892) or the amount that is twice the value of the transaction that is the basis of the violation with respect to which the penalty is imposed;

(ii) For each violation of 22 U.S.C. 2779a, an amount not to exceed $1,055,721 (from $1,028,988), or five times the amount of the prohibited incentive payment, whichever is greater; and

(iii) For each violation of 22 U.S.C. 2780, an amount not to exceed $1,256,607 (from $1,224,787).

https://www.federalregister.gov/documents/2025/01/10/2025-00361/department-of-state-2025-civil-monetary-penalties-inflationary-adjustment

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Interim Final Rule: Targeted Revisions To Certain Parts Of USML Categories II, IV, V, VII Through XIV And XIX Through XXI.

January 17, 2025: 90 Fed. Reg. 5594: The Department of State published an interim final rule in the Federal Register that, after a 240-day delayed effective date, will amend §§ 121.0 and 121.1 of the International Traffic in Arms Regulations (ITAR) by revising certain U.S. Munitions List (USML) definitions, adding new definitions, and revising certain parts of USML Categories II, IV, V, VII through XIV, and XIX through XXI.

USML Category II

In USML Category II, Note 2 to paragraph (a)(5) is revised to correct a typographical error.

USML Category IV

USML Category IV paragraph (c) is revised and paragraphs (c)(1) and (2) are added to more clearly describe the equipment controlled therein, and to differentiate between equipment specially designed for commodities enumerated in paragraphs (a) or (b) of Category IV under the new paragraph (c)(1), and equipment specially designed for improvised explosive devices (IEDs) under the new paragraph (c)(2), similar to how they are differentiated in paragraph 4.b of the Wassenaar Arrangement Munitions List. This amendment also replaces the undefined term “apparatus and devices” with the § 120.40 defined term “equipment.”

USML Category V

USML Category V paragraph (c)(2) is revised to add the CAS Registry Number for pentaborane and to replace the comma after “pentaborane” with a semicolon, in order to clarify this paragraph describes derivatives of carboranes, decaboranes, and pentaborane. Paragraph (f)(4)(x) is revised to correct the CAS Registry Number. Paragraphs (e)(10), (f)(19), and (g)(4) are revised to correct typographical errors.

USML Category VII

Note 3 to USML Category VII is revised to further clarify the universe of ground vehicles described, with no change to the scope of controls. Specifically, the types of vehicular control and locomotion employed are irrelevant when evaluating a vehicle against the control criteria. The Department affirms that although some unmanned ground vehicles, based on their method of control or locomotion, may be referred to by the public colloquially as “robots,” they must still be evaluated against the criteria in USML Category VII.

USML Category VIII

USML Category VIII(h)(1) is revised to clarify which commodities are described therein by incorporating relevant portions of the existing note to paragraph (h)(1). This revision also serves to facilitate reference to the included list of aircraft by other USML paragraphs, and to better align controls with the Department's intent around U.S. Government technology demonstrators. Additionally, it precludes release of commodities from paragraph (h)(1) based solely on their subsequent use in aircraft included in USML Category XXI (pursuant to the procedures therein) or in foreign advanced military aircraft. Foreign advanced military aircraft, as newly defined in § 121.0, include non-U.S. origin aircraft and foreign derivatives of U.S. origin aircraft, either in development or entering production after 2023, with one or more of the following advanced military capabilities: Active Electronically Scanned Array (AESA) fire control radar, integrated signature management, electronic warfare systems, or the ability to engage targets beyond visual range (BVR). The Department further highlights the use of the term “AESA fire control radar” to ensure that AESA weather radars commonly used in civil aviation are clearly excluded from this list of advanced military capabilities. The year 2023 was chosen as the production year in this definition to ensure alignment with the temporary modification to the USML issued on December 4, 2023 (88 FR 84072), and extended on November 26, 2024 (89 FR 93170), which states that parts used in or with the KF-21 continue to be described on the USML.

As practitioners have confused the F-15SE (Silent Eagle) with the F-15E (Strike Eagle), the F-15SE nomenclature is also clarified. Further, the “B1B” is replaced by “B-1.” As the B-1A never entered into production, this change does not change the export classification of existing items. The Department makes this change consistent with the majority of aircraft listed in the paragraph and its intent to include future variants of those aircraft. The Department notes the only aircraft listed with series letters (F-15SE, F/A-18E/F, and EA-18G) in this paragraph intentionally exclude earlier variants (for example, the control does not include the F-15A, which is an F-15 variant developed before the F-15SE). Additionally, the Department adds the MQ-25 and the RQ-170 to the list of aircraft in paragraph (h)(1)(i). The MQ-25 provides a critical military advantage in its ability to support the future Navy carrier air wing and is central to the Navy's strategic Unmanned Campaign Framework. The RQ-170 is a high-altitude, long-endurance, low-observable unmanned aerial vehicle that provides a critical military and intelligence advantage in its ability to perform key intelligence, surveillance, reconnaissance, target acquisition, and electronic warfare functions. Paragraph (h)(1) describes articles used in some of the most advanced U.S. military aircraft. The changes to paragraph (h)(1) ensure those specially designed articles are not released from this entry based on their subsequent use in USML Category XXI aircraft, foreign advanced military aircraft, or U.S. Government (USG) technology demonstrator aircraft.

Ensuring those elements are not released from paragraph (h)(1) based on subsequent use in foreign advanced military aircraft is consistent with the language of § 120.3(a)(2). With this change, the Department treats use of these commodities in foreign advanced military aircraft as it has in their use in advanced U.S. military aircraft. This addition facilitates opportunities for reuse and commonality with partner aircraft by enabling U.S. content to be utilized in those platforms without unnecessary redesigns or unmerited removal from the USML.

The Department further considered amending the language to remove commodities designed exclusively for non-Department of Defense (DoD) USG technology demonstrators from paragraph (h)(1). The Department declines to do so, as such commodities are generally not currently described in paragraph (h)(1). Specifically, USG technology demonstrators are unique among the aircraft listed in paragraph (h)(1), as some technology demonstrators are described on the USML, while others are not. The Department notes commodities used in technology demonstrators are often developed exclusively for those demonstrators or repurposed from other USML or CCL platforms for time and cost savings; those commodities must be reviewed on a case-by-case basis for proper export classification. Specifically, for USG technology demonstrators that are themselves not described on the USML (“these aircraft”), it is generally the case that:

Articles designed for and used only in other aircraft listed in paragraph (h)(1) before and during subsequent unmodified use in these aircraft generally remain described in paragraph (h)(1), as explained by the following analysis:
In the context of paragraph (h)(1), such articles meet the criteria in, and thus are caught by, § 120.41(a)(1) as having properties peculiarly responsible for the controlled characteristic ( e., their use in the listed aircraft), and (a)(2) for their use in or with the other listed aircraft.
In the context of paragraph (h)(1), such articles are not released by § 120.41(b)(3), (4), or (5), as they were originally developed for aircraft described in either USML Category VIII or XXI, and the USG technology demonstrator does not enter production as defined in § 120.43.
Articles designed for, and used in, aircraft subject to the EAR prior to unmodified use in these aircraft are not described in paragraph (h)(1) but may be described elsewhere on the USML, as explained by the following analysis:
In the context of paragraph (h)(1), there are circumstances wherein such articles would be released by § 120.41(b)(3), regardless of meeting the criteria in § 120.41(a).
With contemporaneous documentation, there are circumstances in which the articles would also be released by paragraph (b)(4) or (5).
Articles designed for, and only used in, these aircraft are not described in paragraph (h)(1), but may be described elsewhere on the USML, as explained by the following analysis:
In the context of paragraph (h)(1), such articles meet the criteria in § 120.41(a)(1) as having properties peculiarly responsible for the controlled characteristic ( e., their use in the listed aircraft), but not (a)(2) unless they are used in or with a defense article.
In the context of paragraph (h)(1), such articles are not released by § 120.41(b)(3), as the USG technology demonstrator does not enter production. However, they could be released by paragraph (b)(4), as they were developed with the knowledge they would be used in these aircraft, often in a system that is subject to the EAR.
In contrast, articles designed for, and only used in, USG technology demonstrators described on the USML are described in paragraph (h)(1), as explained in the following analysis:
In the context of paragraph (h)(1), such articles meet the criteria in § 120.41(a)(1) as having properties peculiarly responsible for the controlled characteristic ( e., their use in the listed aircraft), and (a)(2) for their use in or with aircraft described in USML Category VIII.
In the context of paragraph (h)(1), such articles are not released by § 120.41(b)(3), (4), or (5), as they were originally developed for an aircraft described in USML Category VIII. The Department is also amending the text of the current “Note to paragraph (h)(1),” redesignating it as “Note 1 to paragraph to (h)(1),” and adding “Note 2 to paragraph (h)(1).” The addition of “Note 2 to paragraph (h)(1)” outlines an example of the scope of paragraph (h)(1) for articles used in USG technology demonstrators.
With these revisions to paragraph (h)(1) and the notes to paragraph (h)(1), the Department also terminates the temporary modification to Category VIII of the USML that was issued on December 4, 2023 (88 FR 84072) and extended on November 26, 2024 (89 FR 93170).

The Department notes certain commodities designed exclusively for DoD-funded developmental aircraft, including aircraft jointly funded by DoD and another agency, remain defense articles described in paragraph (f) of USML Category VIII.

Paragraph (h)(29) of USML Category VIII is revised to clarify the commodities described therein include both those designed for the aircraft listed and the defense articles described in paragraph (h)(1), with a change in control via the removal of commodities specially designed for USG technology demonstrators.

The note located at the end of USML Category VIII is moved to follow USML Category VIII paragraph (h), renamed “Note 1 to paragraph (h),” and revised for clarity, with no change in scope.

USML Category IX

USML Category IX(e)(2) is placed in reserve to eliminate redundancy. Technical data directly related to the software and databases enumerated in paragraph (b)(4) is already described in paragraph (e)(1).

USML Category X

Developmental exoskeletons have been identified as a technology warranting ITAR control due to the critical military advantage they provide. Thus, Category X is amended by removing paragraph (b) from reserve and adding a new paragraph (b) to describe exoskeletons under development for DoD, along with standard exclusions applied to other developmental articles to provide advance notice to industry and to avoid controlling those that do not provide a critical military advantage.

The Department also amends Category X to align body armor protection levels with the most recent NIJ standard, 0123.00, “Specification for NIJ Ballistic Protection Levels and Associated Test Threats.” All references to “NIJ Type IV” have been updated to NIJ RF3. “Note 1 to paragraph (a)(1)” and “Note to paragraphs (a) and (d)” have also been updated to reference the new standard. “Note to paragraphs (a) and (d)” is redesignated as “Note 1 to paragraphs (a) and (d).”

USML Category XI

USML Category XI paragraphs (c)(10)(i) and (ii) are revised to reflect that certain anti-jam antennas no longer provide a critical military advantage, with increasing commercial utilization applicable to civil GPS resiliency. Following consultations with DoD, the beam switching speed criterion in paragraph (c)(10)(i) is revised from 50 milliseconds down to one millisecond, and the convergence time criterion in paragraph (c)(10)(ii) is revised from one second down to one millisecond, as the Department seeks to control only the most sensitive and effective anti-jam antennas in USML Category XI(c)(10)(i) and (ii). The Department further intends to exclude Controlled Reception Pattern Antennas (CRPAs) for Position, Navigation, and Timing (PNT) from paragraph (c)(10). To implement this, the Department is removing all CRPAs from paragraphs (c)(10)(i) and (ii) and adding paragraphs (c)(10)(v) and (vi) to describe the CRPAs for non-PNT applications that meet the updated criteria used in paragraphs (c)(10)(i) and (ii) the CRPA antennas were moved from. In removing CRPAs for PNT, the Department intends to facilitate civil global navigation system resiliency. CRPAs use multiple elements and advanced signal processing techniques to dynamically control their reception pattern, thereby enhancing signal reception from desired directions and suppressing interference from undesired directions. Generally, in comparing CRPAs to the antennas that remain described in paragraphs (c)(10)(i) and (ii), CRPAs are more optimized to control the reception pattern instead of the transmission beam steering or switching. This is in line with the Position, Navigation, and Timing, Advisory Board's (PNTAB) recommendation to remove CRPAs from the USML. The antennas removed from the USML by these changes are neither subject to multilateral controls nor controlled as munitions in other countries that produce them. Once removed from the USML, these anti-jam antennas will become subject to the EAR under the jurisdiction of the Department of Commerce.

USML Category XII

USML Category XII paragraph (d)(2)(ii) is revised to update the language to reflect the current description of Positioning Service from Precise Positioning Service to Protected Positioning Service (PPS). In the 2021 Federal Radionavigation Plan published by the Departments of Defense, Transportation, and Homeland Security (available at https://rosap.ntl.bts.gov/view/dot/63024), PPS has been updated to “Protected” Positioning Service from the former “Precise” Positioning Service. This change accurately reflects the technology's ability to operate in degraded environments as opposed to legacy encryption abilities that facilitate greater position precision and no longer provide a critical military advantage.

USML Category XIII

USML Category XIII paragraph (b)(4) is revised to update the name of the Unified Cross Domain Management Office (UCDMO) to the National Cross Domain Strategy and Management Office (NCDSMO).

The Department further amends Category XIII to align armor protection levels with the most recent NIJ standard, 0123.00, “Specification for NIJ Ballistic Protection Levels and Associated Test Threats.” All references to “NIJ Level III” are updated to NIJ RF1. As the new RF1 standard corresponds to the previous Type III standard, this is not a significant change in control. The reference in paragraph (m)(10) is also updated to reference the new standard.

Additionally, paragraph (e)(2) is revised for clarification and to add paragraphs (e)(2)(i) and (ii). Category XIII is further revised to add specific fluids to the USML in paragraph (j)(3). Each of these fluids was developed for one or more critical military applications for which existing fluids were unsuitable; by including a specially designed criterion, general-purpose fluids subsequently selected for use in a military application are not described by this control. Lastly, paragraph (m)(9) is amended to clarify the definitions of variables in the equation for E_m.

USML Category XIV

Additional nerve agents and a defoliant are added to USML Category XIV in paragraphs (a)(1)(iv) through (viii) and (j), and controls on Chemical Agent Resistive Coatings (CARC) are clarified in paragraph (f)(7). The nerve agent additions are made pursuant to changes to Schedule 1 of the Chemical Weapons Convention, while the defoliant addition is a constituent of Agent Orange, for which the Department is unaware of current commercial applications.

The clarification of CARC controls in paragraph (f)(7) is made consistent with longstanding policy published on DDTC's website. As CARC is controlled only through the point of application and curing, export applications for CARC must specify the proposed end-users and end-uses, and export licenses for CARC impose limitations on the same. Of note, the control release for CARC that has been applied and cured only applies to USML Category XIV(f)(7); this release does not apply to coatings or materials described elsewhere on the USML. For example, when a USML Category XIII(j)(2) coating is applied to an item subject to the EAR, a DDTC license or other approval continues to be required for the coating, when the item to which the coating was applied is exported, reexported, or retransferred.

USML Category XIX

USML Category XIX paragraphs (d) and (f)(1) are amended to add specific DoD-funded aircraft engines in development that provide a critical military or intelligence advantage, as well as their specially designed parts, components, accessories, and attachments. Specifically, paragraph (d) is split into two parts, paragraphs (d)(1) and (2), and amended to include the XT900, which is a developmental engine resulting from the enumerated HPW3000 technology demonstrator.

The note to paragraph (d) is redesignated as the note to paragraph (d)(1), to continue its applicability to the engines in former paragraph (d) following their movement to paragraph (d)(1), with no change in scope. Paragraph (f)(1) is amended to include specially designed parts, components, accessories, and attachments for the engine now described in paragraph (d)(2), and to incorporate a portion of the note to paragraph (f)(1). The remainder of the note to paragraph (f)(1) is redesignated as “Note 1 to paragraph (f)(1)” and revised for clarity. Paragraph (f)(1) is further amended to clarify that parts, components, accessories, and attachments are not released if common only to a listed engine and an engine designated in USML Category XXI(a), and to add a catch-all control for XA100, XA101, XA102, XA103, and T901 engine hardware. The XA-series engines represent a substantial leap in propulsion capability. Items specially designed for these engines provides a critical military or intelligence advantage in enabling the engines to provide improved thrust-to-weight capability while addressing fuel efficiency, affordability, and sustainment for warfighter operational readiness. The T901 powers the Future Vertical Lift platform and provides 33% more thrust than, but retains the same size as, its predecessor.

Paragraph (f)(2) is amended to clarify the items described in paragraph (f)(2) by replacing a term of art (“hot section components”) with defined regulatory terms (hot section “parts” and “components”), with no change in scope, and to add related cooled structures for combustion chambers and liners. Punctuation is also updated with no change in scope.

USML Category XX

USML Category XX is amended to add paragraphs (a)(9) and (10) to control two new classes of uncrewed, untethered vessels and vehicles that provide a critical military advantage: specifically, those equipped with anti-recovery features, and larger systems with significant range or endurance. Paragraph (a)(10) includes criteria to avoid control of systems below certain weight and performance thresholds the Department assesses are best suited for scientific research or commercial applications. Tethered systems are similarly excluded from both paragraphs (a)(9) and (10).

USML Category XX(b)(2) is revised for clarity, with no change to the scope of the control.

USML Category XXI

USML Category XXI is amended to move the second sentence of paragraph (a) into a new note, and to further clarify the considerations when designating an article in USML Category XXI.

These amendments will take effect 240 days after publication, on September 15, 2025.

In addition to accepting public comment on these USML revisions, the Department is also asking specific questions in the Request for Comments section of the rule’s preamble. The comment period will be open for 60 days after publication. Interested parties may submit comments by March 18, 2025, using one of the methods described in the interim final rule.

https://www.federalregister.gov/documents/2025/01/17/2025-01313/international-traffic-in-arms-regulations-us-munitions-list-targeted-revisions

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DDTC Final Commodity Jurisdiction Determinations Posted to Website

January 6, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s that resulted in a final determination that the subject product was controlled within USML Category XXI.

Readers may find these determinations helpful when performing self-classification work.

Model Name	Manufacturer	Description	Final Determination	Final Determination Date
METSS 2190-S	K&L Gates LLP	Submarine synthetic hydraulic and lubricating fluid for submarines	USML Category XXI(a), and USML Category XXI(b) for directly related technical data and defense services	5/28/2021
Echo Voyager, P/Ns 1717200-1000-1 and 1717401-2000	The Boeing Company	Extra Large Unmanned Undersea Vehicle (XLUUV)	USML Category XXI(a) (and in the second CJ, the same classification for its specially designed parts, components, accessories, and attachments)	8/2/2019 8/2/2023
Slocum Glider, Model LBS-G, P/N ASSY G-1408-DS	Teledyne Webb Research	Underwater automnomous gliding vehicle	USML Category XXI(a)	9/27/2017
Krytox XHT 500AF	The Chemours Company	Perfluorinated grease	USML Category XXI(a), and USML Category XXI(b) for directly related technical data and defense services	5/20/2021
TenCate ABDS	TenCate Advanced Composites, acquired by Toray Composites Materials America	Active blast mitigation system that suppresses vehicle flight caused by IED and mine blasts and significantly increases the protection of occupants.	USML Category XXI(a)	6/17/2014
Liner, Combustion Chamber, Turbine Engine Transition, Part Number LH50905-02	Honeywell International	Transition element between the combustion chamber and the power turbine of an aircraft gas turbine engine	USML Category XXI(a), and USML Category XXI(b) for directly related technical data and defense services	8/19/2021
Gila Strike Multi-Threat Small Arms Ammunition	Reliant Defense, Inc.	Proprietary enhanced penetration round	USML Category XXI(a), and USML Category XXI(b) for directly related technical data and defense services	10/2/2024
MDS-10, Part Number 3130-0002 and MDS-10T, Part Number 3130-0005	WM Industries Inc.	Handheld dual sensor detectors that combine metal detection and ground penetrating radar technologies for the purpose of detecting improvised explosive devices	USML Category XXI(a), and USML Category XXI(b) for directly related technical data and defense services	12/19/2024

https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_kb_article_page&sys_id=6ea6afdcdbc36300529d368d7c96194b

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Compliance Reminder

Annual sales / transfer reports for ITAR MLAs and WDAs are due now if your company files annually for the calendar year.

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DDTC Frequently Asked Questions (FAQs) Related To Registrations With The Department Of State

Q: Can I renew and amend my registration at the same time?

A: Yes, but only if an applicant includes administrative, material, and Mergers, Acquisitions and Divestitures (MAD) changes within the annual renewal submission. However, if the amendment is executed more than 60 days prior to the registration expiration date, then an applicant must submit a standalone amendment via the ‘Amend’ option in DECCS Registration Dashboard.

Q: How were the new fees calculated?

A: The Directorate of Defense Trade Controls (DDTC) conducted a multi-year assessment to calculate the new registration fees. The new registration fees are based on several factors, including the last 15 years of inflation, technological advancements, and advancements in support services.

Q: Are there any special circumstances which the Department will consider to delay full payment of the registration fee?

A: Registrants whose fees are greater than $4000 may appeal to the Department for consideration of an alternate payment schedule. To be considered, registrants must provide proof that the registration fee is greater than 1 percent of the total sales in the given year. "Total sales" includes domestic and international sales and is not limited to sales of items controlled on the USML. Applicants must submit a request for special consideration to DDTC not less than 30 days prior to registration expiration. Any request received within the 30-day window will be automatically disapproved.

Q: When it comes to registration fee calculations, what is a "favorable determination"?

A: A favorable determination is an approval, an approval with provisos (sometimes also referred to as an approval with conditions), or written authorization from the Directorate of Defense Trade Controls (DDTC) to conduct an activity regulated by the International Traffic in Arms Regulations (ITAR). An application that is returned without action or denied is not a type of favorable determination.

Q: How will a new registrant know their fee?

A: The fee for first time registrants is set at $3,000 (manufacturers/exporters and brokers). However, persons registering as a manufacturer/exporter may also simultaneously register as a broker with a consolidated DS-2032 Statement of Registration and not be charged a separate broker registration fee.

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To Japan

January 2, 2025: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Japan has requested to buy up to one thousand two hundred (1,200) AIM-120 (D-3/C-8) Advanced Medium-Range Air-to-Air Missiles (AMRAAM); up to twenty (20) AIM-120D-3 guidance sections, including precise positioning provided by either Selective Availability Anti-Spoofing Module or M-Code; and up to four (4) AIM-120C-8 guidance sections. The following non-MDE items will be included: AMRAAM propulsion sections, warheads, AIM-120 Captive Air Training Missiles (CATM), missile containers, and control section spares; Common Munitions Built-in Test (BIT) Reprogramming Equipment (CMBRE); ADU-891 Adaptor Group Test Sets; munitions support and support equipment; spare and repair parts, consumables, accessories, and repair and return support; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; warranties; US Government and contractor engineering, technical, and logistical support services; and other related elements of logistics and program support. The estimated total cost is $3.64 billion. The principal contractor will be RTX Corporation, located in Tucson, AZ. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/japan-aim-120d-3-and-aim-120c-8-advanced-medium-range-air-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia

January 2, 2025: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia as requested to buy twenty (20) MK 54 MOD 0 Lightweight Torpedo (LWT) all up rounds. The following non-MDE items will also be included: MK 54 MOD 0 LWT spare parts; MK 54 Recoverable Exercise Torpedoes (REXTORP); handling shapes and containers; training; publications; support and test equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total program cost is $78.5 million. The principal contractor will be RTX Integrated Defense Systems, located in Portsmouth, RI. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/kingdom-saudi-arabia-mk-54-mod-0-lightweight-torpedoes

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DSCA Notifies Congress of Potential FMS Sale To Zambia

January 13, 2025: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Republic of Zambia has requested to buy Bell 412 Enhanced Performance exportable medium-lift transport helicopters; radio communication and navigation systems; weather radar and transponder capabilities; qualification and transition training for pilots and maintainers; in-country Contractor Field Service Representatives support; Program Management Reviews; technical assistance and product support; associated aviation ground support equipment; peculiar ground support equipment; hardware; special tools; test equipment; basic issue items; Quality Assurance Team inspections, inventories, validations, and ground run and flight test verification testing; air freight transportation delivery; initial spare, repair, and consumable parts; operator, maintenance, and technical manuals; technical and logistics support services; and other related elements of logistics and program support. The estimated total cost is $100 million, to be funded by a combination of Foreign Military Financing and Zambian national funds. The principal contractor will be Bell Textron, located in Fort Worth, TX. The purchaser typically requires offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/republic-zambia-bell-412-enhanced-performance-exportable-medium-lift

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DSCA Notifies Congress of Potential FMS Sale To Japan

January 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Japan has requested to buy up to sixteen (16) AGM-158B/B-2 Joint Air-to-Surface Standoff Missiles with Extended Range (JASSM-ER). The following non-MDE items will also be included: AGM-158 JASSM Dummy Air Training Missiles (DATM) and containers; JASSM Anti-jam Global Positioning System Receivers (JAGR); munitions support and support equipment; spare parts, consumables and accessories, and repair and return support; integration and test support and equipment; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and equipment; airlift and transportation support; U.S. Government and contractor engineering, technical, and logistics support services; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $39 million. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to Japan.

https://www.dsca.mil/press-media/major-arms-sales/japan-joint-air-surface-standoff-missiles-extended-range

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DSCA Notifies Congress of Potential FMS Sale To Japan

January 15, 2025: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Japan has requested to buy up to one hundred fifty (150) Standard Missile 6 (SM-6) Block I missiles. The following non-MDE items will also be included: MK 21 Mod 3 Vertical Launch System (VLS) canisters; component parts and support equipment; continued Engineering, Integration and Test (EI&T) materiel and support required to produce the SM-6 Block I missiles; special test and handling equipment; training and training equipment and aids; technical publications and data; U.S. Government and contractor engineering and technical assistance, including related studies and analysis support; and other related elements of logistics and program support. The estimated total cost is $900 million. The principal contractor will be RTX Corporation, located in Camden, AR. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/japan-standard-missile-6-sm-6-block-i-missiles

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

Commerce Issues Advance Notice of Proposed Rulemaking to Secure Unmanned Aircraft Systems

January 2, 2025: the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an advance notice of proposed rulemaking (ANPRM) seeking public comment to inform the potential development of a rule to secure and safeguard the information and communication technology and services (ICTS) supply chain for unmanned aircraft systems (UAS), or drones.

With the rapid development of advanced technology, commercial drones are now commonplace across the United States. This ANPRM explains how foreign adversary involvement in UAS ICTS supply chains – including acute threats from the People’s Republic of China (PRC) and Russia – may offer our adversaries the ability to remotely access and manipulate these devices, exposing sensitive U.S. data.

BIS seeks public feedback on several matters outlined in the ANPRM, including: definitions of UAS and components, assessments of how potential classes of ICTS transactions integral to UAS may present undue or unacceptable risks to U.S. national security, evaluations of risk posed by different foreign adversaries, potential processes for the public to request approval to engage in an otherwise prohibited transaction, the economic impact such regulation could have on certain entities, and, where feasible, potential mitigation measures.

https://www.bis.gov/press-release/commerce-issues-advance-notice-proposed-rulemaking-secure-unmanned-aircraft-systems and

https://www.bis.gov/news-updates/search?content_type=All&created=1&field_countries=All&field_learn_support_topics=All&field_news_updates_topic=All&news_search_query=&sort_by=created&sort_order=DESC

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Export Enforcement Releases 2024 Year in Review

January 2, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) Export Enforcement published its annual Year in Review, a compilation of highlights reflecting Export Enforcement’s accomplishments over the past year.

The Year in Review includes numerous initiatives from 2024, including the expansion of the Disruptive Technology Strike Force, which, to date, has brought 26 criminal cases charging sanctions and export control violations, smuggling conspiracies, and other offenses related to the transfer of sensitive information, goods, and military-grade technology to the People’s Republic of China, Russia, and Iran.

The Year in Review also highlights significant criminal and administrative enforcement actions from the past year, including several related to Russian, Chinese, Iranian, and North Korean illicit procurement networks. In addition, the Year in Review describes key partnerships with the interagency, industry, academia, and foreign governments, and it describes updates to the antiboycott enforcement program.

BIS Export Enforcement protects and promotes U.S. national security by aggressively investigating violations of export control and antiboycott regulations and by partnering with industry and academia to facilitate compliance with those regulations.

https://www.bis.gov/media/documents/bis-export-enforcement-year-review-2024 and https://www.bis.gov/news-updates/search?content_type=All&created=1&field_countries=All&field_learn_support_topics=All&field_news_updates_topic=All&news_search_query=&sort_by=created&sort_order=DESC

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Biden-Harris Administration Announces Regulatory Framework for the Responsible Diffusion of Advanced Artificial Intelligence Technology

January 13, 2025: 90 Fed. Reg. 4544: The Department of Commerce’s Bureau of Industry and Security (BIS) announced controls on advanced computing chips and certain closed artificial intelligence (AI) model weights, alongside new license exceptions and updates to the Data Center Validated End User (VEU) authorization. This new regulation serves key U.S. national security and foreign policy interests and supports the Biden-Harris Administration’s broader strategy to cultivate a secure and trusted technology ecosystem for the responsible use and diffusion of AI.

The framework adopts a three-pronged strategy.

First, the rule updates controls for advanced computing chips by requiring authorizations for exports, reexports, and transfers (in-country) involving a broad set of additional countries. However, the rule also includes the following license exceptions and authorizations, which will ensure that commercial transactions that don’t pose national security risks can proceed and the benefits of AI can be broadly shared:

Exceptions for certain allies and partners: New License Exception Artificial Intelligence Authorization (AIA) allows for the export, reexport, or transfer (in-country) of advanced computing chips, without an authorization, to a set of allies and partners. Those destinations, which are listed in paragraph (a) to Supplement No. 5 to Part 740, are Australia, Belgium, Canada, Denmark, Finland, France, Germany, Ireland, Italy, Japan, the Netherlands, New Zealand, Norway, Republic of Korea, Spain, Sweden, Taiwan, the United Kingdom, and the United States.
Exceptions for supply chains:New License Exception Advanced Compute Manufacturing (ACM) allows for the export, reexport, or transfer (in-country) of advanced computing chips, without an authorization, for the purposes of development, production, and storage of these chips, except to arms-embargoed countries. This license exception builds on the Temporary General License from October 2023 rule to prevent disruption of supply chains.
Low volume exception: New License Exception Low Processing Performance (LPP) allows limited amounts of compute to flow globally, except to arms-embargoed countries.
Update to Data Center Validated End User (VEU) Program:The rule further bifurcates Data Center VEUs into:
- Universal VEUs (UVEU):Provides U.S. and certain allied and partner country entities with the opportunity to obtain a single authorization that will allow the company to build data centers around the world without additional authorizations, except in arms-embargoed countries.
- National VEUs (NVEU):Provides entities headquartered outside arms-embargoed countries the opportunity to obtain an authorization that will allow the company to build data centers in specified locations without additional authorizations, except in arms-embargoed countries.

When a license is required to export or reexport chips to a certain destination, license applications will be reviewed under a presumption of approval until the total quantity of controlled chips exported or reexported to that country exceeds a specified allocation. After a country reaches its allocation, applications will be reviewed under a policy of denial. Consistent with previously established policy, a presumption of denial remains in place for arms-embargoed countries, regardless of quantity.

Authorized NVEUs will be able to build data centers up to a specified scale in each country. This allocation is separate from, and not impacted by, the host country’s specified country allocation. Likewise, the low-volume orders are not affected by and do not count against country-level allocations. Authorized UVEUs will be required to keep at least 75% of their controlled advanced chips within the United States and certain allied and partner countries and will be prohibited from installing more than 7% of their controlled chips in any single other country. U.S.-headquartered UVEUs will be required to keep at least 50% of their controlled advanced chips in the United States.

Second, the rule institutes new controls on the model weights of the most advanced closed-weight AI models. These controls will initially apply to the weights of models trained with 10^26 computational operations or more, and authorizations will be required to export, reexport, or transfer (in-country) such weights to a broad set of countries. Additionally, the rule creates a new foreign direct product rule that applies these controls to certain model weights produced abroad using advanced computing chips made with U.S. technology or equipment. As with advanced computing chips, however, this rule includes several license exceptions for model weights:

Exception for deployments by U.S., ally and partner-headquartered entities: New License Exception Artificial Intelligence Authorization (AIA) allows for the export, reexport, or transfer (in-country) of otherwise controlled closed AI model weights, without an authorization, by companies headquartered in the United States and certain allies and partners (see list above), except to an arms-embargoed country.
Exception for open models:Models with widely available model weights (i.e., open-weight models) are not subject to controls. Additionally, the model weights of closed models that are less powerful than the most advanced open-weight models, even if they exceed the 10^26 threshold, are not controlled.

Third, BIS will impose security conditions to safeguard the storage of the most advanced models in destinations to protect U.S. national security and to mitigate the risk of diversion for advanced computing chips.

https://www.bis.gov/press-release/biden-harris-administration-announces-regulatory-framework-responsible-diffusion and https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion

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Commerce Finalizes Rule to Secure Connected Vehicle Supply Chains from Foreign Adversary Threats

January 14, 2025: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a final rule prohibiting certain transactions involving the sale or import of connected vehicles integrating specific pieces of hardware and software, or those components sold separately, with a sufficient nexus to the People’s Republic of China (PRC) or Russia.

BIS and its Office of Information and Communications Technology and Services (OICTS) have found that certain technologies originating from the PRC or Russia present an undue and unacceptable risk to U.S. national security. This action represents the culmination of a months-long regulatory process to design, seek public input on, and ultimately finalize a measure to protect drivers and passengers on American roads.

The final rule establishes that hardware and software integrated into the Vehicle Connectivity System (VCS) and software integrated into the Automated Driving System (ADS), the systems in vehicles that allow for external connectivity and autonomous driving capabilities, present an undue and unacceptable risk to national security when designed, developed, manufactured, or supplied by persons with a sufficient nexus to the PRC or Russia. Malicious access to these critical supply chains could allow our foreign adversaries to extract sensitive data, including personal information about vehicle drivers or owners, and remotely manipulate vehicles.

At this time, given the complexity of the commercial vehicle supply chain, the final rule applies only to passenger vehicles (defined as those under 10,001 pounds). BIS recognizes the acute national security threat presented by foreign adversary involvement in the commercial vehicle supply chain and intends to issue a separate rulemaking addressing the technologies present in connected commercial vehicles – including in trucks and buses – in the near future.

This final rule prohibits the import of VCS hardware or connected vehicles containing such hardware, and the import and sale of vehicles containing VCS or ADS software, with a sufficient nexus to the PRC or Russia. VCS is defined as the set of systems that allow the vehicle to communicate externally, including telematics control units, Bluetooth, cellular, satellite, and Wi-Fi modules. ADS includes the components that collectively allow a highly autonomous vehicle to operate without a driver.

The rule also prohibits manufacturers with a sufficient nexus to the PRC or Russia from selling new connected vehicles that incorporate VCS hardware or software or ADS software in the United States, even if the vehicle was made in the United States.

The software-related prohibitions will take effect for Model Year 2027. The hardware-related prohibitions will take effect for Model Year 2030, or January 1, 2029, for units without a model year. Prohibitions on the sale of connected vehicles by manufacturers with a sufficient nexus to the PRC or Russia, even if manufactured in the United States, take effect for Model Year 2027.

The rule requires certain importers and manufacturers to submit annual Declarations of Conformity to certify their compliance with the prohibitions. The final rule allows Commerce to issue General Authorizations for certain types of transactions posing lower risk. It also allows regulated parties to seek Specific Authorizations permitting them to engage in otherwise prohibited transactions, as well as advisory opinions to ask BIS for a determination if a prospective transaction may fall within the scope of the rule.

The final rule follows a Notice of Proposed Rulemaking (NPRM) published by BIS on September 26, 2024, and an Advance Notice of Proposed Rulemaking (ANPRM) published by BIS on March 1, 2024.

https://www.bis.gov/press-release/commerce-finalizes-rule-secure-connected-vehicle-supply-chains-foreign-adversary

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Commerce Strengthens Restrictions on Advanced Computing Semiconductors to Enhance Foundry Due Diligence and Prevent Diversion to PRC

January 15, 2025: 90 Fed. Reg. 5298: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released two rules: one that updates export controls on advanced computing semiconductors, and another that places additional entities in the People’s Republic of China (PRC) and Singapore on the Entity List.

These rule’s reinforce and build on the October 7, 2022, October 17, 2023, and December 2, 2024, controls to restrict the PRC’s ability to obtain certain high-end chips critical for military advantage. These updates are necessary to maintain the effectiveness of these controls, close loopholes, and ensure they remain durable.

Among other changes, the rules:

Impose a broader license requirement for foundries and packaging companies seeking to export certain advanced chips, unless one of three conditions is met:
- The export is to a trusted “Approved” or “Authorized” integrated circuit (IC) designer, who attests that the chips fall below the relevant performance threshold;
- The chip is packaged by a front-end fabricator in a location outside of Macau or a destination in Country Group D:5 and the fabricator verifies the transistor count of the final chip; or
- The chip is packaged by an “Approved” outsourced semiconductor assembly and test services (OSAT) company that verifies the transistor count of the final chip.
Create a process for new companies to be added to the list of Approved IC designers and OSATs.
Improve reporting for transactions involving newer customers who may pose a heightened risk of diversion.
Update other parts of the Export Administration Regulations (EAR), including the recent AI Diffusion rule, to ensure that license exceptions are only available for transactions involving approved or authorized IC designers.
Make technical corrections to the December 2 export controls, including to update the definition of “advanced-node integrated circuit” in § 772.1 for Dynamic Random-Access Memory (DRAM) chips.
Add 16 entities to the Entity List, including AI companies like Sophgo Technologies Ltd., that are acting at the behest of Beijing to further the PRC’s goals of indigenous advanced chip production, which poses a risk to U.S. and allied national security.

These controls were crafted to mitigate the PRC’s efforts to obtain high-end advanced computing semiconductors necessary to enable the development and production of technologies such as AI used in military applications. Advanced AI capabilities – facilitated by supercomputing, built on advanced semiconductors – present U.S. national security concerns because they can be used to improve the speed and accuracy of military decision making, planning, and logistics. These capabilities may also be used for cognitive electronic warfare, radar, signals intelligence, jamming, and to support facial recognition surveillance systems for human rights violations and abuses.

https://www.bis.gov/press-release/commerce-strengthens-restrictions-advanced-computing-semiconductors-enhance-foundry

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Commerce Implements New Controls to Address National Security Risks Related to Biotechnology

January 15, 2025: 90 Fed. Reg. 4612: The Department of Commerce’s Bureau of Industry and Security (BIS) released an Interim Final Rule (IFR) implementing targeted export controls on certain laboratory instruments. The United States recognizes that ensuring the responsible use of biotechnology, particularly when combined with advances in artificial intelligence (AI) and data science, is essential to safeguard public health, agriculture and food production, and the environment. At the same time, the United States needs to address the benefits and risks of biotechnology given the potential that its use, particularly when coupled with AI and biological design tools, could strengthen the military capabilities of countries of concern and pose threats to U.S. national security.

This IFR controls the following instruments:

High-parameter and spectral flow cytometers and cell sorters, which are used to simultaneously measure multiple features of individual cells or particles, allowing scientists to rapidly produce large, high-information biological datasets.
Certain liquid chromatography mass spectrometers (LC/MS) specially designed for proteomics, the study of all or a significant portion of proteins produced and/or modified by an organism to elucidate the interactions, function, composition, and structures of proteins and their cellular activities.

While this IFR imposes new license requirements for these instruments, license exceptions will be available for certain destinations. Exporters will also be required to file Electronic Export Information in the Automated Export System for certain exports.

This IFR, which takes immediate effect, is the latest step in the Biden administration’s ongoing efforts to address national security and foreign policy concerns related to critical technologies. BIS invites public comments on this IFR, which must be submitted no later than 60 days after the rule’s publication in the Federal Register. Information on submitting comments can be found in the “addresses” portion of the rule’s preamble.

https://www.bis.gov/press-release/commerce-implements-new-controls-address-national-security-risks-related

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U.S. Census Bureau

Happy New Year 2025

January 1, 2025: This is a friendly reminder to ensure the Estimated Date of Export is reported with the correct year. To avoid the Automated Export System (AES) generating the Compliance Alert - Shipment Reported Late, please report the year 2025 for the current AES shipments.

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Schedule B and Harmonized Tariff Schedule (HTS) Updated in the Automated Export System (AES)

January 2, 2025: Effective immediately, the Schedule B, Harmonized Tariff Schedule (HTS), and HTS Codes That Are Not Valid for AES tables have been updated to accept the changes to the January 1, 2025 codes.

AES will accept shipments with outdated codes during a grace period for 30 days beyond the expiration date of December 31, 2024. Reporting an outdated code after the 30-day grace period will result in a fatal error.

The ACE AESDirect program has been updated with the 2025 codes and will accept shipments with outdated codes during the grace period as well.

The 2025 Schedule B and HTS tables are available for downloading at:

https://www.census.gov/foreign-trade/aes/concordance.html

The current list of HTS codes that are not valid for AES are available at:

https://www.census.gov/foreign-trade/aes/documentlibrary/concordance/hts-not-for-aes.txt

Editor’s note: It is best practice to validate your schedule B codes each January.

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Updates to the AES Commodity Filing Response Messages – Appendix A: Response Code 5C2/5C3

January 7, 2025: CSMS # 63644218 - Updates to the AES Commodity Filing Response Messages – Appendix A: Response Code 5C2/5C3

U.S. Customs and Border Protection (CBP) recently published the following updates to the Automated Export System Trade Interface Requirements – Appendix A:

Response Code: 5C2

Narrative Text: CAT XXI DETERMINATION NBR UNKNOWN
Severity: FATAL
Proprietary Record ID/Data Elements: Input ODT Record/DDTC Commodity Jurisdiction (CJ) Number
X.12 Segment ID/Data Elements: X117
Reason: The License Code/USML Category XXI Code declared is one that requires a DDTC Category XXI determination number on the ODT record either reported empty, unknown or the Date of Export is greater than the superseded date in AES.
Resolution: The DDTC Category XXI determination number reported on the ODT record must be a known value in AES. Verify, correct, and retransmit. If DDTC has advised your commodity export is classified in Category XXI, but you do not have a unique case number, you may contact the DDTC Response Team for assistance at ddtccustomerservice@state.gov or (202) 663-1282.

Response Code: 5C3

Narrative Text: DDTC USML CATEG 55 NOT ELIG FOR LIC TYPE
Severity: FATAL
Proprietary Record ID/Data Elements: Input CL1 Record/License Code/License Exemption Code; Input ODT Record/DDTC USML Category Code
X.12 Segment ID/Data Elements: X105; X107
Reason: The DDTC USML Category Code 55 (Articles Not Listed in the International Traffic in Arms Regulations (ITAR)), may not be used with License Code/License Exemption Code entered.
Resolution: When the DDTC USML Category Code 55 (Articles Not Listed in the International Traffic in Arms (ITAR)) is reported but is not available for use with the License Code/License Exemption Code entered. See ‘Appendix L- DDTC USML Category Codes’ to determine the category code to report.
For further assistance, contact the licensing agency. The Response Team at the Department of State’s Directorate of Defense Trade Controls can be reached for this purpose at 202-663-1282 or ddtccustomerservice@state.gov.

Editor’s note: In December, we advised that Census reported updates to the AES system for reporting items classified as USML XXI via a Commodity Jurisdiction determination issued by the Department of State, the only avenue for declaration of USML XXI on EEI filings. In order to use Category XXI, you must also list the CJ case number in the EEI record.

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Tips on How to Resolve AES Response Messages

January 21, 2025: When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. Though the shipment is accepted, the filer may still receive a Verify Message, Compliance Alert, Informational Message or Warning Message along with their ITN. However, if the shipment is rejected, a Fatal Error notification is received and must be corrected to receive a valid ITN.

To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.

Response Code: 303

Narrative: To Be Sold En Route Indicator Must be Y or N

Severity: Fatal

Reason: The Party Type is identified as Ultimate Consignee and the To Be Sold En Route Indicator is not reported as Yes or No.

Resolution: The Ultimate Consignee information must be declared on an EEI including a valid To Be Sold En Route Indicator. If the Ultimate Consignee is known and reported, set the To Be Sold En Route Indicator to No. If the cargo is to be sold en route and the Ultimate Consignee is not known at the time of export, then set the To Be Sold En Route Indicator to Yes.

Verify the Ultimate Consignee and the To Be Sold En Route Indicator, correct the shipment and resubmit.

Response Code: 505

Narrative: Value of Goods Contains Non-Numerics

Severity: Fatal

Reason: The Value of Goods reported contains non-numerics or spaces.

Resolution: The Value of Goods must be reported as numerics on the EEI.

Verify the Value of Goods, correct the shipment and resubmit.

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NEW BIS LICENSE TYPES C73 – License Exceptions Artificial Intelligence Authorization (AIA) and C74 Advanced Compute Manufacturing (ACM)

January 28, 2025: On Monday, January 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) put on public inspection at the Office of the Federal Register an interim final rule with an effective date of Monday, January 13, 2025 and a compliance date of May 15 for most provisions. The IFR was published in the Federal Register on Thursday, January 16 2024 (https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion).

Among other actions, this interim final rule established new controls on advanced AI chips exceeding the technical thresholds in ECCN 3A090.a and also creates License Exceptions Artificial Intelligence Authorization (AIA) and Advanced Compute Manufacturing (ACM).

New License Code C73 (AIA)

An update has been made to AES to create new License Code C73 Artificial Intelligence Authorization (AIA) which authorizes the export, reexport, or transfer (in-country) of eligible advanced computing chips and associated software and technology to entities located in a destination listed in paragraph (a) of supplement no. 5 to part 740 as long as they certify compliance with specific requirements provided in EAR 740.27.

The full terms of License Exception AIA are described in § 740.27.

AES filers must adhere to the following new reporting when using C73 (AIA) to prevent the return of fatal errors from AES:

Report License Code: C73 Artificial Intelligence Authorization (AIA)
Allowable ECCNs: 3A001.z, 3A090.a, 3A090.z, 3D001, 4A003.z, 4A004.z, 4A005.z, 4A090.a, 4A090.z, 4D001, 4D090, 4E001, 4E091, 5A002.z, 5A004.z, 5A992.z, 5D002.z, 5D992.z, 5E002, and 5E992
Allowable countries: All Countries listed in Supplement 5 to part 740 (Australia, Belgium, Canada, Denmark, Finland, France, Germany, Ireland, Italy, Japan, the Netherlands, New Zealand, Norway, Republic of Korea, Spain, Sweden, Taiwan, the United Kingdom, and the United States)
Allowable Export Information Codes: All except UG
Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)

New License Code C74 (ACM)

An update has been made to AES to create new License Code C74 Advanced Compute Manufacturing (ACM) which authorizes the export, reexport, and transfer (in-country) of eligible items to a ‘private sector end user’ that is located in a destination not listed in Country Group D:5 or Macau, for the purposes of development, production, and storage of these chips, except for or in arms embargoed countries (D:5 and Macau).

The full terms of License Exception ACM are described in § 740.28.

AES filers must adhere to the following new reporting when using C74 (ACM) to prevent the return of fatal errors from AES:

Report License Code: C74 Advanced Compute Manufacturing (ACM)
Allowable ECCNs: 3A001.z, 3A090, 3D001, 3E001, 4A003.z, 4A004.z, 4A005.z, 4A090, 4D001, 4D090, 4E001, 5A002.z, 5A004.z, 5A992.z, 5D002.z, 5D992.z, 5E002, and 5E992
Allowable countries: All Countries except Macau and destinations listed in Country Group D:5
Allowable Export Information Codes: All except UG
Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)

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NEW BIS LICENSE TYPE C75 – (LPP) License Exception Low Processing Performance (LPP)

January 29, 2025: On Monday, January 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) put on public inspection at the Office of the Federal Register an interim final rule with an effective date of Monday, January 13, 2025 and a compliance date of May 15 for most provisions. The IFR was published in the Federal Register on Thursday, January 16, 2024 (https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion ).

Among other actions, this interim final rule established new License Exception Low Processing Performance (LPP).

New License Code C75 (LPP)

An update has been made to AES to create new License Codes C75 “Low Processing Performance” (LPP), which authorizes certain export and reexport (no transfer (in-country) of specified items in § 740.29(b) of the EAR. Allows limited quantities of advanced ICs (i.e., quantities well below the amount necessary to train the most advanced AI models) to flow globally to ultimate consignees in destinations other than those of Country Group D:5 or Macau. The threshold for LLP exception has been set at 26,900,000 Total Processing Performance (TPPs) of ECCN 3A090.a, 4A090.a, and corresponding .z items per end user, per calendar year. This license exception is not available for exports or reexports made through distributors or for in country transfers. Ultimate consignees must notify BIS when they have reached the annual TPP allocation limit.

The full terms of License Exception LPP are described in § 740.29.

AES filers must adhere to the following new reporting when using C75 (LPP) to prevent the return of fatal errors from AES:

Report License Code: C75 Low Processing Performance (LPP)
Allowable ECCNs: 3A001.z.1.a, z.2.a, z.3.a, z.4.a; 3A090.a; 4A003.z.1.a, z.2.a; 4A004.z.1; 4A005.z.1; 4A090.a; 5A004.z.1.a, z.2.a; and 5A992.z.1
Allowable countries: All Countries except Macau and destinations listed in Country Group D:5 Allowable Export Information Codes: All except UG

Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)

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NEW BIS LICENSE TYPES C76 – Universal Validated End User (UVEU) and C77 National Validated End User (NVEU)

January 29, 2025: On Monday, January 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) put on public inspection at the Office of the Federal Register an interim final rule with an effective date of Monday, January 13, 2025 and a compliance date of May 16 for most provisions. The IFR is expected to publish in the Federal Register on Thursday, January 16, 2024 (https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion). Among other actions, this interim final rule established new License Exceptions C76 Universal Validated End User (UVEU) and C77 National Validated End User (NVEU).

New License Code C76 (UVEU)

An update has been made to AES to create new License Codes C76 Universal Validated End User (UVEU) which provides the data centers that own their advanced computing capacity with a single authorization that will allow a UVEU to build DCs around the world, except in Macau or destinations specified in Country Group D:5, provided that the UVEU maintains its status by following the guidelines in supplement no. 10 to part 748. The UVEU is responsible for ensuring it complies with the applicable AI TPP geographic allocations. To receive UVEU status, a DC that owns its advanced computing capacity must certify that it will follow the guidelines outlined in supplement no. 10 to part 748 and go through an intensive application process. As previously noted, if the owner of the advanced compute cannot directly certify to all of the application information requested in § 748.15, it must include in its VEU application to BIS the identities of other entities involved in the DC operations.

The full terms of License Exception UVEU are described in § 748.15.

AES filers must adhere to the following new reporting when using C76 (UVEU) to prevent the return of fatal errors from AES:

Report License Code: C76 Universal Validated End User (UVEU)
Allowable ECCNs: See Supplement 7 to part 748 for specific end users and ECCNs.
Allowable countries: All Countries except D:5 and Macau
Allowable Export Information Codes: All except UG
Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)

New License Code C77 (NVEU)

An update has been made to AES to create new License Codes C77 National Validated End User (NVEU) which is available to all entities headquartered in or located in a destination in Country Groups A, B, or D:1-D:4, except Macau or destinations specified in Country Group D:5, as described in revised § 748.15(b)(2). New paragraph (a)(2)(iii) of § 748.15 describes the requirements to obtain an NVEU. In order to receive NVEU Authorization, a data center operator that owns its advanced computing capacity must apply to BIS and go through an intensive application process that will be subject to interagency review. Information required to be submitted to become a VEU is described in supplement no. 8 to part 748, some provisions of which are revised by this rule, including an update to paragraph (B)(2) of the supplement to require information about business activities and corporate relationships with government or military organizations in Macau and destinations specified Country Group D:5, e.g., direct sales to or contracts with such entities.

Approved applicants for the NVEU Authorization will be listed in the EAR as NVEUs in supplement no. 7 to part 748. This listing will serve to notify exporters and reexporters that the NVEU location can receive exports and reexports under this authorization. The NVEU may choose whether to list a corporate address or a physical address of the new data center location. NVEUs will be subject to the cumulative TPP allocations identified above.

The full terms of License Exception UVEU are described in § 748.15.

AES filers must adhere to the following new reporting when using C77 (NVEU) to prevent the return of fatal errors from AES:

Report License Code: C77 National Validated End User (NVEU)
Allowable ECCNs: All EXCEPT 600 series and ECCNs with a reason for control: Missile Technology and/or Crime Control
Allowable countries: All Countries except D:5 and Macau
Allowable Export Information Codes: All except UG

Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)

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Implementation of the Census Bureau Voluntary Self-Disclosure (VSD) Form

January 30, 2025: In an effort to improve the Voluntary Self Disclosure (VSD) process, the Census Bureau’s Trade Regulations Branch (TRB) has piloted the use of a fillable VSD form since August 2024. TRB’s evaluation of the pilot has shown that the data received is more timely and complete, and allows for more efficient processing of VSDs. The feedback received from VSD submitters has been positive and TRB is implementing the use of the VSD Form on March 3, 2025.

The fillable VSD form will collect the following data required under Section 30.74 of the Foreign Trade Regulations:

The kind of violation involved, for example, failure to file EEI, failure to correct fatal errors, failure to file timely corrections;
Describe all data that was either not reported or reported incorrectly;
An explanation of when and how the violations occurred;
The complete identities and addresses of all individuals and entities, whether foreign or domestic, involved in the activities giving rise to the violations;
If the party in violation was notified of the violation by any federal agency(ies);
Were the exports subject to any export controls from federal agency(ies)?;
A description of any mitigating factors;
Corrective measures taken; and
ITNs of the missed and/or corrected shipments.

The implementation of this fillable VSD form will allow companies to submit the necessary VSD information in a uniform format.

LATEST SANCTIONS FINES & PENALTIES

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

Fines and Penalties

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

January 6, 2025: 90 Fed. Reg. 599: On May 30, 2024, in the U.S. District Court for the Western District of Pennsylvania, Derby Clerfe (“Clerfe”) was convicted of violating 18 U.S.C. 371. Specifically, Clerfe pled guilty to conspiring with others to export from the United States to Haiti nine handguns without the required licenses and without filing Electronic Export Information in the Automated Export System. As a result of his conviction, the Court sentenced Clerfe to one year of probation. The Director of the Office of Export Enforcement has decided to deny Clerfe's export privileges under the Regulations for a period of two years from the date of Clerfe's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Clerfe had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/01/06/2024-31656/in-the-matter-of-derby-clerfe-9-garden-terrace-pittsburgh-pa-15521-order-denying-export-privileges

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January 6, 2025: 90 Fed. Reg. 597: On February 16, 2023, in the U.S. District Court for the Southern District of Texas, Joel Alejandro Garza-Corona (“Garza-Corona”) was convicted of violating 18 U.S.C. 554(a). Specifically, Garza-Corona was convicted of smuggling 2,399 rounds of assorted ammunition from the United States to Mexico without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the court sentenced him to 40 months in prison. The Director of the Office of Export Enforcement decided to deny Garza-Corona's export privileges under the Regulations for a period of eight years from the date of Garza-Corona's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Garza-Corona had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/01/06/2024-31669/in-the-matter-of-joel-alejandro-garza-corona-inmate-number-26658-510-fci-ashland-po-box-6001-ashland

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January 6, 2025: 90 Fed. Reg. 597: On September 6, 2023, in the U.S. District Court for the District of Maryland, Eric Nana Kofi Ampong-Coker (“Ampong-Coker”) was convicted of violating 50 U.S.C. 4819. Specifically, Ampong-Coker was convicted of knowingly and willfully attempting to export one (1) SCCY Industries LL.C., Model CPX-2 9mm handgun; one (1) Mossberg 9mm handgun; one (1) Smith & Wesson 9mm handgun; one (1) FIS Product, Model XD-9 9mm handgun; and one (1) Sarsilmaz (Sar Arms), 9mm handgun, which weapons were designated under ECCN 0A501 from the United States to Ghana without the required licenses. As a result of his conviction, the court sentenced Among-Coker to 30 months in prison and two years of supervised release. The Director of the Office of Export Enforcement decided to deny Ampong-Coker's export privileges under the Regulations for a period of 10 years from the date of Ampong-Coker's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Ampong-Coker had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/01/06/2024-31667/in-the-matter-of-eric-nana-kofi-ampong-coker-inmate-number-16722-510-fci-cumberland-po-box-1000

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January 6, 2025: 90 Fed. Reg. 599: On June 11, 2024, in the U.S. District Court for the Eastern District of Pennsylvania, Daniel Ray Lane (“Lane”), was convicted of violating 18 U.S.C. 371 and the International Emergency Economic Powers Act (50 U.S.C 1701, et seq.) (“IEEPA”). Specifically, Lane was convicted of conspiring to sell sanctioned Iranian petroleum/crude oil to a refinery in China. As a result of his conviction, the Court sentenced Lane to 45 months of imprisonment and three years of supervised release.

The Director of the Office of Export Enforcement decided to deny Lane's export privileges under the Regulations for a period of 10 years from the date of Lane's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Lane had an interest at the time of his conviction.

https://www.federalregister.gov/documents/2025/01/06/2024-31654/in-the-matter-of-daniel-ray-lane-inmate-number-60019-177-fci-texarkana-federal-correctional

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January 8, 2025: Nikolay Goltsev, 38, of Montreal, Canada, was sentenced to 40 months in prison for conspiring to commit export control violations. Goltsev masterminded a global procurement scheme on behalf of sanctioned Russian companies, including Russian military companies. Some of the electronic components shipped by Goltsev were later found in seized Russian weapons platforms and signals intelligence equipment in Ukraine.

https://www.justice.gov/opa/pr/canadian-national-sentenced-40-months-multimillion-dollar-export-control-scheme

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January 17, 2025: As part of a coordinated enforcement effort, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed approximately $2.5 million in combined civil penalties against Haas Automation, Inc. (Haas) for alleged and apparent violations of U.S. export controls and sanctions laws, including illegal shipments of Computer Numerical Control (CNC) machine parts to Entity-Listed parties in Russia and China. The transactions charged by BIS involved parties that were added to the Entity List for supporting the defense sectors of China or Russia.

As part of a settlement agreement with Haas, BIS issued an order imposing an administrative penalty of $1.5 million, as well as an ongoing audit and reporting requirement. In addition to the BIS penalty, Haas entered a corresponding settlement with OFAC whereby Haas agreed to a $1,044,781 civil penalty to resolve apparent violations of OFAC’s sanctions regulations involving Russia and Ukraine.

Headquartered in Oxnard, California, Haas is a privately held manufacturer of machine tools and related parts, including CNC vertical and horizontal machining centers and CNC lathes. CNC machines and parts have a wide range of potential applications, including uses across the electronics, transportation, oil and gas, aerospace, marine, and military and defense industries.

On 32 occasions between April 2019 and March 2024, Haas violated the EAR by selling CNC machine parts designated as EAR99, through Haas’s authorized distributors, for export, reexport, or transfer (in-country) to defense sector parties that were on the BIS Entity List in China, including Beijing University of Aeronautics and Astronautics (also known as Beihang University), Shandong Institute of Space Electronic Technology, and China Electronics Technology Group Corporation 14th Research Institute (CETC 14). Additionally, Haas violated the EAR by making nine sales to two defense sector parties on the Entity List in Russia—DJSC Factory Krasnoe Znamya and JSC LEMZ R&P Corporation—between January 2020 and November 2021.

https://www.bis.gov/press-release/haas-automation-pay-over-25-million-combined-civil-penalties-bis-and-ofac-prohibited

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

January 16, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $1,076,923 settlement with a Miami, Florida-based natural U.S. person and their real estate company Family International Realty LLC regarding their potential civil liability for apparent violations of OFAC's Ukraine/Russia-related sanctions. Between 2018 and 2023, Family International Realty and its owner engaged in a willful scheme to evade OFAC sanctions by concealing the property interest of two sanctioned Russian oligarchs in luxury condominiums and profiting from the rental and sale of the properties, thereby committing 73 apparent violations of Executive Order 13685. The settlement amount reflects OFAC's determination that the conduct at issue was egregious and was not voluntarily self-disclosed.

https://ofac.treasury.gov/media/933941/download?inline and

https://ofac.treasury.gov/recent-actions/20250116

Sanctions

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

January 6, 2025: 90. Fed. Reg. 559: The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 entities under 13 entries to the Entity List. These entries are listed on the Entity List under the destinations of Burma (1), China, People's Republic of (China) (11), and Pakistan (1). These entities have been determined by the U.S. Government to be acting contrary to the national security and/or foreign policy interests of the United States. This rule also amends the EAR by making certain editorial corrections and clarifications. BIS is making the corrections and clarifications in order to minimize confusion and not impede the free flow of commerce.

The following Entities have been added:

Burma:

Telecom International Myanmar Company Limited.

China:

Chengdu RML Technology Co., Ltd.;
Chengdu Yaguang Electronics Co., Ltd.;
Chinese Academy of Sciences Changchun Institute of Optics, Fine Mechanics, and Physics;
Hefei Starwave Communication Technology Co., Ltd.;
Ji Hua Laboratory;
Nanjing Simite Optical Instruments Co., Ltd.;
Peng Cheng Laboratory;
Shanghai Institute of Optics and Fine Mechanics;
Suzhou Ultranano Precision Optoelectronics Technology Co., Ltd.;
Wuhu Kewei Zhaofu Electronics Co., Ltd.; and
Yaguang Technology Group Co., Ltd.

Pakistan:

Emerging Future Solutions Private Limited.

https://www.federalregister.gov/documents/2025/01/06/2024-31468/revisions-to-the-entity-list and

https://www.bis.gov/news-updates/search?content_type=All&created=1&field_countries=All&field_learn_support_topics=All&field_news_updates_topic=All&news_search_query=&sort_by=created&sort_order=DESC

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January 16, 2025: 90 Fed. Reg. 4617: The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 11 entities under 11 entries to the Entity List. These entries are listed on the Entity List under the destination of China, People's Republic of (China) (11). These entities have been determined by the U.S. Government to be acting contrary to the national security and/or foreign policy interests of the United States. This rule also revises one existing entry on the Entity List under the destination of India.

China:

Beijing Keyi Hongyuan Optoelectronics Co., Ltd.;
Beijing Lingxin Intelligent Technology Co., Ltd.;
Beijing Yuanyin Intelligent Technology Co., Ltd.;
Beijing Zhipu Future Technology Co., Ltd.;
Beijing Zhipu Huazhang Technology Co., Ltd.;
Beijing Zhipu Linghang Technology Co., Ltd.;
Beijing Zhipu Qingyan Technology Co., Ltd.;
Hangzhou Zhipu Huazhang Technology Co., Ltd.;
Nanjing Zhihu Information Technology Co., Ltd.;
Shanghai Zhipu Huanyu Technology Co., Ltd.; and
Shenzhen Zhipu Future Technology Co., Ltd.

https://www.federalregister.gov/documents/2025/01/16/2025-00704/addition-of-entities-to-and-revision-of-entry-on-the-entity-list

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January 16, 2024: 90. Fed. Reg. 4621: The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 16 entities to the Entity List, under the destinations of China, People's Republic of (China) (14) and Singapore (2). These entities have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States.

China:

Chengdu Suanze Technology Co., Ltd.;
Fujian Sophon Technology Co., Ltd.;
Fujian Suanxin Technology Co., Ltd.;
Jiangsu Suanxin Technology Co., Ltd.;
Qingdao Sophgo Technology Co., Ltd.;
Quliang Electronics Co., Ltd.;
Shanghai Suanhu Technology Co., Ltd.;
Sophgo Technologies Ltd.;
Sophon Technology (Beijing) Co., Ltd.;
Suanli (Fujian) Technology Co., Ltd.;
Tianjin Shunhua Technology Co., Ltd.;
Wuhan Suanneng Technology Co., Ltd.;
Wuxi Suanneng Technology Co., Ltd.; and
Xiamen Sophgo Technologies Limited.

Singapore:

Sophgo Technologies Pte.

https://www.federalregister.gov/documents/2025/01/16/2025-00480/additions-to-the-entity-list

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

January 3, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Integrity Technology Group, Incorporated (Integrity Tech), a Beijing-based cybersecurity company, for its role in multiple computer intrusion incidents against U.S. victims. These incidents have been publicly attributed to Flax Typhoon, a Chinese malicious state-sponsored cyber group that has been active since at least 2021, often targeting organizations within U.S. critical infrastructure sectors.

Chinese malicious cyber actors continue to be one of the most active and most persistent threats to U.S. national security, as highlighted in the most recent Office of the Director of National Intelligence Annual Threat Assessment. These actors continue to target U.S. government systems as part of their efforts, including the recent targeting of Treasury’s own IT infrastructure.

The following entity has been added to OFAC’s SDN List:

Integrity Technology Group, Incorporated of China.

https://home.treasury.gov/news/press-releases/jy2769 and

https://ofac.treasury.gov/recent-actions/20250103

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January 6, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24 to expand authorizations for activities and transactions in Syria following December 8, 2024. This action underscores the United States’ commitment to ensuring that U.S. sanctions do not impede activities to meet basic human needs, including the provision of public services or humanitarian assistance. This authorization is for six months, as the U.S. government continues to monitor the evolving situation on the ground.

GENERAL LICENSE NO. 24: “Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances”

(a) The following transactions that are prohibited by the Syrian Sanctions Regulations, 31 CFR part 542 (SySR), the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR) are authorized through 12:01 a.m. eastern daylight time, July 7, 2025:

(1) transactions with governing institutions in Syria following December 8, 2024;

(2) transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria; and

(3) transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.

Additionally, OFAC has also issued eight new Syria Frequently Asked Questions (FAQs 1205 - 1212).

Syria FAQ 1205:

Q: What is the purpose of Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances") and what does it authorize?

A: GL 24 is intended to ensure that sanctions do not impede essential governance-related services in Syria following the fall of Bashar al-Assad on December 8, 2024, including for the provision of public services or certain transactions related to energy or personal remittances. GL 24 complements OFAC's existing humanitarian-related authorizations by authorizing the following transactions, with some conditions and exceptions, through July 7, 2025:

transactions with governing institutions in Syria following December 8, 2024;
transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria; and
transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.

GL 24 authorizes the foregoing under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR). It does not relieve any person from compliance with other Federal laws or regulations, including the International Traffic in Arms Regulations (ITAR) or the Export Administration Regulations (EAR) administered by the Department of Commerce.

Syria FAQ 1206:

Q: What Syrian entities are included in the scope of "governing institutions" for the purposes of Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances")?

A: Syrian governing institutions include departments, agencies, and government-run public service providers (including public hospitals, schools, and utilities) at the federal, regional, or local level in Syria following December 8, 2024, including entities involved with Hay’at Tahrir al Sham (HTS) across all geographic areas of Syria.

GL 24 does not authorize transactions involving military or intelligence entities, or any persons acting on behalf of such entities.

Syria FAQ 1207:

Q: What types of transactions are included in the authorization related to Syrian governing institutions in Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances")?

A: GL 24 authorizes transactions under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR).

GL 24 generally authorizes the following transactions, with the exclusion of military or intelligence entities or those acting for or on their behalf:

providing services to, or paying for services received from, Syrian governing institutions, such as the Ministry of Health, the Ministry of Education, or the Ministry of Water Resources, even if the ministry or leadership of the institution is blocked;
payment of taxes, fees, or import duties to Syrian governing institutions, even if the ministry or leadership is blocked;
purchase or receipt of permits, licenses, public utility services, or other public services;
payment of salaries or wages to employees of governing institutions in Syria, provided such employees are not designated on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List); and
negotiating contracts or other agreements with Syrian governing institutions.

Syria FAQ 1208:

Q: Does Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances") authorize activities and transactions with a governing institution in Syria run by or led by a designated person?

A: Yes. GL 24 authorizes transactions with governing institutions in Syria, with some conditions and exceptions, through July 7, 2025, even if a designated individual has a leadership role in that governing institution.

For example, if a company engaging in otherwise authorized activity needs to make a customs payment to a governing institution led by a blocked individual following December 8, 2024, that payment is authorized.

Syria FAQ 1209:

Q: Even after the issuance of Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances"), may I still rely on existing sanctions authorizations for the provision of humanitarian aid?

A: Yes. The authorization in GL 24 may overlap with the authorizations in existing GLs issued under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR), including:

transactions in support of certain nongovernmental organizations' activities (31 CFR §§ 594.520; 597.516; 542.516);
official business of the U.S. Government (31 CFR §§ 594.518; 597.514; 542.522);
official business of certain international organizations (31 CFR §§ 594.519; 597.515; 542.513); and
activities in certain economic sectors in specified areas of northeast and northwest Syria (31 CFR § 542.533).

OFAC general licenses are "self-executing," meaning that persons who determine that certain activities are authorized under a GL may proceed without further assurance from OFAC. Where multiple authorizations may apply, U.S. persons may rely on the broadest applicable authorization.

With respect to transactions in support of certain nongovernmental organizations’ activities, U.S. depository institutions, U.S. registered brokers or dealers in securities, and U.S. registered money transmitters can process such transactions and may rely on the statements of their customers that such transactions are authorized unless they know or have reason to know a transaction is not authorized. For more information, including an overview of authorized humanitarian activities in addition to GL 24, please review FAQs 231 and 938, and the OFAC Syria Compliance Communique.

Syria FAQ 1210:

Q: Does Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances") remove the restrictions placed on Syria under the State Sponsor of Terrorism (SST) designation?

A: No. SST restrictions on Syria remain in place.

Syria FAQ 1211:

Q: Can foreign governments or companies donate or provide subsidized fuel to Syria without facing exposure to U.S. sanctions?

A: Yes. Syria General License (GL) 24 authorizes transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria. This may include, for example, the donation of gasoline to Syrian refineries, and power plants.

However, authorizations for this activity under the general license do not relieve persons from compliance with any other laws or requirements of other federal agencies or international organizations. For example, the export or reexport of petroleum, petroleum products, natural gas, and other commodities to Syria may require additional authorization from the Department of Commerce if such items are U.S.-origin or otherwise subject to the Export Administration Regulations (EAR).

Syria FAQ 1212:

Q: Are international organizations and nongovernmental organizations authorized to conduct transitional justice activities in Syria?

A: Yes. Activities to support the rule of law, accountability, and transparency are broadly authorized under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR), including transactions in support of certain nongovernmental (NGO) activities (31 CFR §§ 594.520; 597.516; 542.516), official business of the U.S. Government (31 CFR §§ 594.518; 597.514; 542.522), and official business of certain international organizations (31 CFR §§ 594.519; 597.515; 542.513) by employees, grantees, or contractors thereof.

For example, the NGO activities general licenses authorize transactions in support of activities to support democracy building, including activities to support rule of law, citizen participation, government accountability and transparency, human rights and fundamental freedoms, access to information, and civil society development projects; and activities to support disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevention, and conflict resolution programs.

https://home.treasury.gov/news/press-releases/jy2770 and

https://ofac.treasury.gov/media/933861/download?inline and

https://ofac.treasury.gov/faqs/added/2025-01-06

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January 7, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Mohammad Hamdan Daglo Mousa (Hemedti), the leader of Sudan’s Rapid Support Forces (RSF), under Executive Order (E.O.) 14098, “Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition.” For nearly two years, Hemedti’s RSF has engaged in a brutal armed conflict with the Sudanese Armed Forces for control of Sudan, killing tens of thousands, displacing 12 million Sudanese, and triggering widespread starvation.

In addition, OFAC sanctioned seven companies, and one individual linked to the RSF. The RSF's ability to acquire military equipment and generate finances continue to fuel the conflict in Sudan. Capital Tap Holding L.L.C. (Capital Tap Holding), based in the United Arab Emirates (UAE), has provided money and weapons to the RSF.

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

Ahmmed, Abu Dharr Abdul Nabi Habiballa of the United Arab Emirates; and
Mousa, Mohammed Hamdan Daglo of Sudan.

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

Al Jil Alqadem General Trading L.L.C. of the United Arab Emirates;
Al Zumoroud And Al Yaqoot Gold and Jewellers Trading of the United Arab Emirates;
Capital Tap General Trading L.L.C. of the United Arab Emirates;
Capital Tap Holding L.L.C. of the United Arab Emirates;
Capital Tap Management and Consultancies L.L.C. of the United Arab Emirates;
Creative Python L.L.C. of the United Arab Emirates; and
Horizon Advanced Solutions General Trading – Sole Proprietorship L.L.C of the United Arab Emirates.

https://ofac.treasury.gov/recent-actions/20250107 and

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

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January 7, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Antal Rogan, a senior Hungarian government official, for his involvement in corruption in Hungary. He is being designated pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related General License 13L, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024."

GENERAL LICENSE NO. 13L: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”

(a) U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, April 9, 2025.

The following individual has been added to OFAC’s SDN List:

Rogan, Antal of Hungary.

https://ofac.treasury.gov/recent-actions/20250107 and

https://home.treasury.gov/news/press-releases/jy2773 and

https://ofac.treasury.gov/media/933871/download?inline

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January 10, 2025: The U.S. Department of the Treasury took sweeping action to fulfill the G7 commitment to reduce Russian revenues from energy, including blocking two major Russian oil producers. This action also imposes sanctions on an unprecedented number of oil-carrying vessels, many of which are part of the “shadow fleet,” opaque traders of Russian oil, Russia-based oilfield service providers, and Russian energy officials. This action is underpinned by the issuance of a new determination that authorizes sanctions pursuant to Executive Order (E.O.) 14024 against persons operating or having operated in the energy sector of the Russian Federation economy. These actions substantially increase the sanctions risks associated with the Russian oil trade.

Please see full list of sanctioned individuals, entities, and vessels at the link below.

OFAC has also issued Russia-related General License 8L, "Authorizing the Wind Down of Transactions Related to Energy;" Russia-related General License 115A, "Authorizing Certain Transactions Related to Civil Nuclear Energy;" Russia-related General License 117, "Authorizing the Wind Down of Transactions Involving Gazprom Neft, Surgutneftegas, and Certain Additional Entities Blocked on January 10, 2025;" Russia-related General License 118, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Gazprom Neft, Surgutneftegas, and Certain Additional Entities Blocked on January 10, 2025;" Russia-related General License 119, "Authorizing Certain Transactions Involving Public Joint Stock Company Gazprom Neft Related to Diplomatic and Consular Mission Operations Outside of the Russian Federation;" Russia-related General License 120, "Authorizing Limited Safety and Environmental Transactions and the Unloading of Cargo Involving Certain Persons or Vessels Blocked on January 10, 2025;" Russia-related General License 121, "Authorizing Petroleum Services Related to Certain Projects;" and Russia-/Ukraine-related General License 26, "Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations."

GENERAL LICENSE NO. 8L: Authorizing the Wind Down of Transactions Related to Energy

(a) All transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are ordinarily incident and necessary to the wind down of any transaction related to energy are authorized, through 12:01 a.m. eastern daylight time, March 12, 2025:

(1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;

(2) Public Joint Stock Company Bank Financial Corporation Otkritie;

(3) Sovcombank Open Joint Stock Company;

(4) Public Joint Stock Company Sberbank of Russia;

(5) VTB Bank Public Joint Stock Company;

(6) Joint Stock Company Alfa-Bank;

(7) Public Joint Stock Company Rosbank;

(8) Bank Zenit Public Joint Stock Company;

(9) Bank Saint-Petersburg Public Joint Stock Company;

(10) National Clearing Center (NCC);

(11) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or

(12) the Central Bank of the Russian Federation.

(b) For the purposes of this general license, the term “related to energy” means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources.

GENERAL LICENSE NO. 115A: Authorizing Certain Transactions Related to Civil Nuclear Energy

(1) Gazpombank Joint Stock Company;

(2) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;

(3) Public Joint Stock Company Bank Financial Corporation Otkritie;

(4) Sovcombank Open Joint Stock Company;

(5) Public Joint Stock Company Sberbank of Russia;

(6) VTB Bank Public Joint Stock Company;

(7) Joint Stock Company Alfa-Bank;

(8) Public Joint Stock Company Rosbank;

(9) Bank Zenit Public Joint Stock Company;

(10) Bank Saint-Petersburg Public Joint Stock Company;

(11) National Clearing Center (NCC);

(12) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or

(13) the Central Bank of the Russian Federation.

(b) For the purposes of this general license, the term “related to civil nuclear energy” means transactions undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024.

GENERAL LICENSE NO. 117: Authorizing the Wind Down of Transactions Involving Gazprom Neft, Surgutneftegas, and Certain Additional Entities Blocked on January 10, 2025

(a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the blocked entities listed in the Annex to this general license, or any entity in which those blocked entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time, February 27, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).

GENERAL LICENSE NO. 118: Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Gazprom Neft, Surgutneftegas, and Certain Additional Entities Blocked on January 10, 2025

(a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by the following blocked entities (“Covered Debt or Equity”) to a non-U.S. person are authorized through 12:01 a.m. eastern standard time, February 27, 2025:

(1) Ingosstrakh Insurance Company;

(2) Limited Liability Company Plant for the Production of Propeller Steering Columns Sapphire;

(3) Open Joint Stock Company Volzhsky Abrasive;

(4) Public Joint Stock Company Gazprom Neft;

(5) Surgutneftegas; or

(6) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

(b) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to facilitating, clearing, and settling trades of Covered Debt or Equity that were placed prior to 4:00 p.m. eastern standard time, January 10, 2025 are authorized through 12:01 a.m. eastern standard time, February 27, 2025.

(c) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, January 10, 2025 that (i) include a blocked person described in paragraph (a) of this general license as a counterparty or (ii) are linked to Covered Debt or Equity are authorized through 12:01 a.m. eastern standard time, February 27, 2025, provided that any payments to a blocked person are made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR

GENERAL LICENSE NO. 119: Authorizing Certain Transactions Involving Public Joint Stock Company Gazprom Neft Related to Diplomatic and Consular Mission Operations Outside of the Russian Federation

(a) all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the official business of diplomatic or consular missions located outside of the Russian Federation and involving Public Joint Stock Company Gazprom Neft (Gazprom Neft), or any entity in which Gazprom Neft owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time February 27, 2025.

GENERAL LICENSE NO. 120: Authorizing Limited Safety and Environmental Transactions and the Unloading of Cargo Involving Certain Persons or Vessels Blocked on January 10, 2025

(a) all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to one or more of the following activities involving the blocked persons listed in the Annex to this general license, and any entity in which those blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time, February 27, 2025, provided that any payment to a blocked person must be made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR):

(1) The safe docking and anchoring in port of any vessels in which any person listed in the Annex to this general license has a property interest (the “blocked vessels”);

(2) The preservation of the health or safety of the crew of any of the blocked vessels; or (

3) Emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels.

(b) all transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the delivery and offloading of cargo involving the blocked persons listed in the Annex to this general license are authorized through 12:01 a.m. eastern standard time, February 27, 2025, provided that the cargo was loaded prior to January 10, 2025.

GENERAL LICENSE NO. 121: Authorizing Petroleum Services Related to Certain Projects

(a) all transactions prohibited by the determination of January 10, 2025 made pursuant to section 1(a)(ii) of Executive Order 14071 (“Prohibition on Petroleum Services”) that are related to the projects listed below are authorized until 12:01 a.m. eastern daylight time June 28, 2025:

(1) Caspian Pipeline Consortium;

(2) Tengizchevroil; or

(3) Sakhalin-2.

GENERAL LICENSE NO. 26: Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations

(a) all transactions prohibited by Executive Order (E.O.) 13662 involving one or more blocked persons listed in the Annex to this general license, or any entity in which those blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are authorized or exempt under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions authorized by a general or specific license, are authorized.

Furthermore, OFAC has issued five new, Russia-related Frequently Asked Questions (FAQs 1213 - 1217)

FAQ 1213:

Q: For the purposes of the determination of January 10, 2025 made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination"), what is meant by the term "energy sector of the Russian Federation economy"?

A: On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian Federation economy. For purposes of the January 2025 Energy Sector Determination, OFAC anticipates publishing regulations defining the term "energy sector of the Russian Federation economy" to include activities such as the procurement, exploration, extraction, drilling, mining, harvesting, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, manufacturing, testing, financing, distribution, purchase or transport to, from, or involving the Russian Federation, of petroleum, including crude oil, lease condensates, unfinished oils, natural gas, liquefied natural gas, natural gas liquids, or petroleum products, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels; the development, production, testing, generation, transmission, financing, or exchange of power, through any means, including nuclear, electrical, thermal, and renewable, to, from, or involving the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the energy sector of the Russian Federation economy.

This definition is similar to the energy sector definition set forth under the Ukraine-/Russia-Related sanctions in 31 CFR 589.311 but includes additional language identifying specific activities and petroleum products, reflecting developments since the Department of the Treasury issued a determination pursuant to section 1(a)(i) of Executive Order 13662 on July 16, 2014. OFAC intends to update the SDN List to reflect whether persons have been designated pursuant to E.O. 14024, E.O. 13662, or both.

FAQ 1214:

Q: Does the determination of January 10, 2025, made pursuant to Executive Order (E.O.) 14024 (the "January 2025 Energy Sector Determination") mean that all persons that operate or have operated in this sector of the Russian Federation economy are sanctioned by OFAC?

A: No. On January 10, 2025, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the energy sector of the Russian Federation economy.

A sector determination pursuant to E.O. 14024 exposes persons that operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector.

FAQ 1215:

Q: Why did OFAC issue General License (GL) 26 ("Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations") in the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589 (URSR)?

A: GL 26 applies to transactions involving specified persons identified in the Annex to GL 26, who are designated under both the URSR and the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR). The purpose of GL 26 is to ensure that transactions authorized or exempt under the RuHSR, including transactions authorized by a general or specific license, that involve those specified persons are also authorized under the URSR, to the extent such transactions are prohibited by Executive Order (E.O.) 13662. However, GL 26 does not authorize any transaction prohibited by a directive issued pursuant to E.O. 13662, as incorporated into sections 589.202 through 589.205 of the URSR, or any transaction involving any person blocked pursuant to the RuHSR or the URSR other than the specified persons, unless separately authorized.

FAQ 1216:

Q: What action did Treasury take on January 10, 2025 with regard to the provision of petroleum services to Russia?

A: In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services ("the Petroleum Services Determination"). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination will take effect at 12:01 a.m. eastern standard time on February 27, 2025. See FAQ 1217 for additional information.

OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia’s ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia’s domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.

Concurrently, OFAC issued GL 121 to authorize any petroleum services that would otherwise be prohibited by the Petroleum Services Determination related to the operations of the Caspian Pipeline Consortium, Sakhalin II, or Tengizchevroil, (2) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (3) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (4) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.

FAQ 1217:

Q: I am a U.S. service provider. Following the January 10, 2025 determinations under Executive Order (E.O.) 14024 and E.O. 14071 (the Energy Sector Determination and Petroleum Services Determination, respectively), am I still authorized to provide certain services relating to the maritime transport of Russian crude oil and Russian petroleum products to a non-sanctioned person operating in the energy sector of the Russian economy, so long as the crude oil or petroleum products are purchased at or below the price cap?

A: Yes, as long as the provision of services does not involve an entity blocked pursuant to E.O. 14024 and is not otherwise prohibited by OFAC sanctions. The price cap policy does not authorize 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, unless separately authorized. For more information on the price cap policy, please see OFAC's price cap policy guidance.

See FAQ 1216 for more information on The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services. See FAQs 1213 and 1214 for more information on the January 2025 Energy Sector Determination, issued pursuant to E.O. 14024.

https://ofac.treasury.gov/media/933926/download?inline

https://home.treasury.gov/news/press-releases/jy2777

https://ofac.treasury.gov/media/933791/download?inline

https://ofac.treasury.gov/media/933881/download?inline

https://ofac.treasury.gov/media/933771/download?inline

https://ofac.treasury.gov/media/933776/download?inline

https://ofac.treasury.gov/media/933781/download?inline

https://ofac.treasury.gov/media/933786/download?inline

https://ofac.treasury.gov/media/933886/download?inline

https://ofac.treasury.gov/media/933891/download?inline and

https://ofac.treasury.gov/faqs/added/2025-01-10

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January 10, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned eight Venezuelan officials who lead key economic and security agencies enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela. The individuals sanctioned, pursuant to Executive Order (E.O.) 13692, as amended, include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company, and Maduro’s Minister of Transportation and president of the Venezuelan Consortium of Aeronautical Industries and Air Services (CONVIASA), the state-owned airline. In addition, OFAC sanctioned high-level Venezuelan officials in the military and police who lead entities with roles in carrying out Maduro’s repression and human rights abuses against democratic actors.

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

Castillo Rengifo, Manuel Enrique of Venezuela;
Ferrer Sandrea, Danny Ramon of Venezuela;
Figuera Valdez, Jose Ramon of Venezuela;
Obregon Perez, Hector Andres of Venezuela;
Osorio Guzman, Felix Ramon of Venezuela;
Rico Gonzalez, Douglas Arnoldo of Venezuela;
Salazar Bello, Jhonny Rafael of Venezuela; and
Velasquez Araguayan, Ramon Celestino of Venezuela.

https://home.treasury.gov/news/press-releases/jy2778 and

https://ofac.treasury.gov/recent-actions/20250110

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January 15, 2025: The U.S. Department of the Treasury moved against Russian efforts to evade U.S. sanctions. This action targets a sanctions evasion scheme established between actors in Russia and the People’s Republic of China (PRC) to facilitate cross-border payments for sensitive goods. In addition, Treasury designated a Kyrgyz Republic-based financial institution that coordinated with Russian officials and a U.S.-designated bank to implement a sanctions evasion scheme.

Treasury also reinforced the grave risks foreign persons face in continuing to work with Russia’s military-industrial complex by re-designating pursuant to Executive Order (E.O.) 13662 almost 100 entities already designated pursuant to E.O. 14024. As a result of these entities’ designation pursuant to E.O. 13662, foreign persons, including foreign financial institutions, that knowingly facilitate significant transactions for or on behalf of any of these entities could be subject to mandatory secondary sanctions under the Ukraine-/Russia-related sanctions program.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has amended its regulations to implement for 2025 the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. This regulatory amendment adjusts for inflation the maximum amount of the civil monetary penalties that may be assessed under relevant OFAC regulations. The regulatory amendment is published in the Federal Register and is effective as of January 15, 2025.

OFAC also has issued Russia-related General License 122, "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on January 15, 2025;" Russia-related General License 123, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Wafangdian Bearing Company Limited;" and Russia-/Ukraine-related General License 26A, "Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations."

GENERAL LICENSE NO. 122: “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on January 15, 2025”

(a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked entities are authorized through 12:01 a.m. eastern standard time, March 1, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR):

(1) Haucore Ltd;

(2) Limited Liability Company Management Metallurgical Company Steel;

(3) Mining And Chemical Complex Federal State Unitary Enterprise;

(4) OJSC Keremet Bank;

(5) Oke Precision Cutting Tools Co Ltd;

(6) Public Joint Stock Company Nadezhdinskiy Metallurgicheskiy Zavod;

(7) Star Rapid Manufacturing Co Ltd;

(8) Wafangdian Bearing Company Limited; or

(9) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

GENERAL LICENSE NO. 123: “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Wafangdian Bearing Company Limited”

(a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by Wafangdian Bearing Company Limited (Wafangdian), or any entity in which Wafangdian owns, directly or indirectly, a 50 percent or greater interest, (“Covered Debt or Equity”) to a non-U.S. person are authorized through 12:01 a.m. eastern standard time, March 1, 2025.

(b) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to facilitating, clearing, and settling trades of Covered Debt or Equity that were placed prior to 4:00 p.m. eastern standard time, January 15, 2025 are authorized through 12:01 a.m. eastern standard time, March 1, 2025.

(c) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, January 15, 2025 that (i) include a blocked person described in paragraph (a) of this general license as a counterparty or (ii) are linked to Covered Debt or Equity are authorized through 12:01 a.m. eastern standard time, March 1, 2025, provided that any payments to a blocked person are made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).

GENERAL LICENSE NO. 26A: “Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations”

(a) All transactions prohibited by Executive Order (E.O.) 13662 involving one or more blocked persons listed in the Annex to this general license, or any entity in which those blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are authorized or exempt under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions authorized by a general or specific license, are authorized.

Please see link below for full list of sanctioned entities and individuals,

https://home.treasury.gov/news/press-releases/jy2785 and

https://ofac.treasury.gov/media/933936/download?inline

https://ofac.treasury.gov/media/933916/download?inline

https://ofac.treasury.gov/media/933921/download?inline

https://ofac.treasury.gov/media/933911/download?inline and

https://ofac.treasury.gov/recent-actions/20250115

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January 16, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Abdel Fattah Al-Burhan (Burhan), the leader of the Sudanese Armed Forces (SAF), under Executive Order (E.O.) 14098, “Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition.” This action follows the designation of the leader of the Rapid Support Forces (RSF), Mohammad Hamdan Daglo Mousa (Hemedti), on January 7, 2025. In addition, OFAC is one company and one individual involved in weapons procurement on behalf of the Defense Industries System (DIS), a procurement arm of the SAF that OFAC sanctioned in June 2023.

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

Abdalla, Ahmed of the United Arab Emirates; and
Al-burhan, Abdel Fattah of Sudan.

The following entity has been added to OFAC’s SDN List:

Portex Trade Limited of China.

https://home.treasury.gov/news/press-releases/jy2789

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January 16, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two individuals and four entities for generating illicit revenue for the Democratic People’s Republic of Korea (DPRK) government.

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

Jong, In Chol of Laos; and
Son, Syong Sik of China.

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

Chonsurim Trading Corporation of North Korea;
Department 53 of the Ministry of The Peoples Armed Forces of North Korea;
Korea Osong Shipping Corporation; and
Liaoning China Trade Industry Co., Ltd.

https://home.treasury.gov/news/press-releases/jy2790

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January 16, 2025: The President signed a new Executive Order (E.O.), "Taking Additional Steps with Respect to the Situation in Syria." The President also signed another new E.O., "Strengthening and Promoting Innovation in the Nation's Cybersecurity."

https://ofac.treasury.gov/media/933951/download?inline and

https://ofac.treasury.gov/media/933946/download?inline

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January 17, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated five individuals and one entity that facilitate Republika Srpska (RS) President Milorad Dodik (Dodik) and his family’s efforts to enrich themselves at the public’s expense. This action also targets eight individuals who, at Dodik’s direction, organized and executed the commemoration of “Republika Srpska Day” (RS Day) in January 2024, in contravention to the principles of the Dayton Peace Agreement (DPA) and which the Bosnia and Herzegovina (BiH) Constitutional Court (CC) ruled unconstitutional.

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

Bojanic, Radmila of Bosnia and Herzegovina;
Corovic, Pavle of Bosnia and Herzegovina;
Dodik, Sinsia of Bosnia and Herzegovina;
Gujanicic, Marko of Bosnia and Herzegovina; and
Reljin, Nemanja of Bosnia and Herzegovina.

The following entity has been added to OFAC’s SDN List:

SEE MEDIA RESEARCH LTD of Cyprus.

https://ofac.treasury.gov/recent-actions/20250117 and

https://home.treasury.gov/news/press-releases/jy2793

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January 17, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Yin Kecheng, a Shanghai-based cyber actor who was involved with the recent Department of the Treasury network compromise. Additionally, OFAC sanctioned Sichuan Juxinhe Network Technology Co., LTD., a Sichuan-based cybersecurity company with direct involvement in the Salt Typhoon cyber group, which recently compromised the network infrastructure of multiple major U.S. telecommunication and internet service provider companies. People’s Republic of China-linked (PRC) malicious cyber actors continue to target U.S. government systems, including the recent targeting of Treasury’s information technology (IT) systems, as well as sensitive U.S. critical infrastructure. As highlighted in the most recent Office of the Director of National Intelligence Annual Threat Assessment, Chinese state-backed cyber actors continue to present some of the greatest and most persistent threats to U.S. national security.

The following individual has been added to OFAC’s SDN List:

Yin, Kecheng of China.

The following entity has been added to OFAC’s SDN List:

Sichuan Juxinhe Network Technology Co., Ltd. of China.

OFAC has issued Counter Terrorism General License 32, "Authorizing the Wind Down of Transactions Involving Yemen Kuwait Bank for Trade and Investment Y.S.C."

GENERAL LICENSE NO. 32: Authorizing the Wind Down of Transactions Involving Yemen Kuwait Bank for Trade and Investment Y.S.C

(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), that are ordinarily incident and necessary to the wind down of any transaction involving Yemen Kuwait Bank for Trade and Investment Y.S.C (Yemen Kuwait Bank), or any entity in which Yemen Kuwait Bank owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time, February 16, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the GTSR.

https://home.treasury.gov/news/press-releases/jy2792 and

https://ofac.treasury.gov/media/933961/download?inline

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January 24, 2025: On January 20, 2025, the President signed a new Executive Order (E.O.), "Initial Rescissions Of Harmful Executive Orders And Actions," which, among other actions, revoked E.O. 14115, "Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank." To implement the President's revocation of E.O. 14115, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed the West Bank-Related Sanctions program from its website and removed all persons designated under E.O. 14115 from the Specially Designated Nationals and Blocked Persons List (SDN List). All property and interests in property blocked under E.O. 14115 are unblocked.

https://ofac.treasury.gov/media/933976/download?inline and

https://ofac.treasury.gov/media/932576/download?inline

JANUARY 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES Read More »

DECEMBER 2024 EXPORT CONTROLS AND COMPLIANCE UPDATES

This newsletter is a listing of the latest changes in export control regulations through December 31, 2024. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.

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

persons denied export privileges by the United States Government.

REGULATORY UPDATES

President

President Biden Continued the National Emergency with Respect to the Global Illicit Drug Trade

December 11, 2024: On December 15, 2021, by Executive Order 14059, the President declared a national emergency pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by global illicit drug trafficking.

The trafficking into the United States of illicit drugs, including fentanyl and other synthetic opioids, is causing the deaths of tens of thousands of Americans annually, as well as countless more non-fatal overdoses with their own tragic human toll. Drug cartels, transnational criminal organizations, and their facilitators are the primary sources of illicit drugs and precursor chemicals that fuel the current opioid epidemic, as well as drug-related violence that harms our communities. International drug trafficking — including the illicit production, global sale, and widespread distribution of illegal drugs; the rise of extremely potent drugs such as fentanyl and other synthetic opioids; as well as the growing role of Internet-based drug sales — continues to pose an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States. For this reason, the national emergency declared in Executive Order 14059 of December 15, 2021, must continue in effect beyond December 15, 2024. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden continued for 1 year the national emergency declared in Executive Order 14059 with respect to global illicit drug trafficking.

https://www.whitehouse.gov/briefing-room/presidential-actions/2024/12/11/press-release-notice-to-the-congress-on-the-continuation-of-the-national-emergency-with-respect-to-the-global-illicit-drug-trade/ and

https://www.whitehouse.gov/briefing-room/presidential-actions/

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President Biden Continued the National Emergency with Respect to Serious Human Rights Abuse and Corruption

December 11, 2024: On December 20, 2017, by Executive Order 13818, the President declared a national emergency with respect to serious human rights abuse and corruption around the world and, pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), took related steps to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States.

The prevalence and severity of human rights abuse and corruption that have their source, in whole or in substantial part, outside the United States, continue to pose an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States. For this reason, the national emergency declared on December 20, 2017, must continue in effect beyond December 20, 2024. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden continued for 1 year the national emergency declared in Executive Order 13818 with respect to serious human rights abuse and corruption.

https://www.whitehouse.gov/briefing-room/presidential-actions/2024/12/11/notice-to-the-congress-on-the-continuation-of-the-national-emergency-with-respect-to-serious-human-rights-abuse-and-corruption/ and

https://www.whitehouse.gov/briefing-room/presidential-actions/

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

Pay.gov To No Longer Accept Amazon Pay Payments

December 5, 2024: After February 22, 2025, Pay.gov will no longer accept Amazon Pay as a valid payment option. Please be sure to have a different form of payment available when paying for a new or renewed Registration.

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

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Public Notice: 12542 - Final Rule: DDTC Registration Fees

December 6, 2024: 89 Fed. Reg. 99081: On December 10, 2024, the Department of State published a final rule, regarding changes to the three tiers of Directorate of Defense Trade Controls (DDTC) registration fees. The new regulation will go into effect on January 9, 2025.

New Registrants

Effective January 9, 2025, first-time registrants will pay the $3000 Tier 1 fee to register with DDTC.

Registration Renewals

For registrations scheduled for renewal, DDTC will continue to send the standard e-mail reminder notifications (90 and 30 days prior to expiration) requesting registrants to log into the Defense Export Control and Compliance System (DECCS) to view the renewal fee and begin the renewal application.

Current registrations expiring on or after March 31, 2025, will be issued standard reminder notifications under the new fee structure included in the final rule.

Registrants issued 90-day reminder notifications with the fee structure under the prior regulation may pay the amount listed in DECCS under DDTC’s prior fee structure.

The final rule’s revised registration fees are as follows.

(1) Tier 1: The first tier is a set registration fee of $3,000 per year. This new registration fee amount applies to first time registrants. It also applies to those renewing registrations and for whom the Department did not issue a favorable determination on a license application or other request for authorization during the 12-month period ending 90 days prior to the expiration of the current registration.

The Tier 1 registration fee also applies to registrants who are wholly exempt from income tax pursuant to 26 U.S.C. 501(c)(3), such as non-profit organizations. Such registrants must attach proof of tax-exempt status (for example, an Internal Revenue Service (IRS) certification form) for the registration fee to be reduced to a Tier 1 amount. The IRS certification must apply to all entities, subsidiaries, and affiliates listed in the registration submission.

(2) Tier 2: The second tier is a set registration fee of $4,000 for registrants renewing their registrations who have submitted license applications or other requests for authorization and received five or fewer favorable determinations during the 12-month period ending 90 days prior to the expiration of their current registration.

(3) Tier 3: The third tier is a calculated registration fee for registrants who have submitted license applications or other requests for authorization and received more than five favorable determinations during the 12-month period ending 90 days prior to the expiration of their current registration. For these registrants, the registration fee calculation is $4,000 plus $1,100 times the total number of favorable determinations over five.

For potential discounts for Tier 1 or Tier 3 registrants, see below.

All registration payments must be completed electronically, through the DECCS Registration application. Once DDTC reviews and issues the registration submission, a “Make Payment” button will appear on your DECCS Registration dashboard.

DDTC recommends all registrants frequently check their DECCS Registration payment portal and email regarding their registration’s payment status. For more guidance on how to make a registration payment, accepted payment methods, and payment status, review the Registration User Guides.

Tier 1 Discount

DDTC is instituting a one-year initiative for qualifying Tier 1 registrants who may petition DDTC for a $500 discount, for a total registration fee of $2,500.

To qualify, Tier 1 registrants must provide some form of proof that $3,000 constitutes 1 percent or more of their total revenue for the last calendar year. DDTC does not prescribe a certain set of documents for this purpose. Examples may include relevant documentation, or a signed attestation (subject to penalties under law for submitting a false statement) by a senior officer empowered by the registrant stating that $3000 constitutes 1 percent or more of their total revenue for the registrant’s last calendar year. Registrants who do not provide sufficient proof in the form of documentation or attestation may not receive the discount. DDTC will make efforts to contact those who have requested the discount, but who did not provide sufficient proof.

For purposes of this discount, “total revenue” is the total amount of income and is not limited to sales of ITAR controlled defense articles. Applicants must submit a discount request at least 30 calendar days prior to expiration of their current registration term. Such requests are encouraged to be made well in advance of 30 days to allow DDTC to review the request, and to contact the requestor if necessary or if sufficient proof was not provided.

At the end of the one-year pilot period the Department will assess the impact of the initiative and consider an extension of the special consideration initiative.

Tier 3 Discount

The Department is maintaining its 3% Total License Value discount for Tier 3 registrants. If the registration fee calculated using the Tier 3 formula listed is greater than 3 percent of the total value of all approvals, the registration fee will be revised to either 3 percent of the total value of all applications or $4,000, whichever is greater.

https://www.federalregister.gov/documents/2024/12/10/2024-29032/international-traffic-in-arms-regulations-registration-fees and

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

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DDTC Name And Address Changes Posted To Website

December 16, 2024: 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:

Address change of Raytheon Systems France S.A.R.L. from 175 Rue Jean-Jacques Rousseau, Issy-les-Moulineaux, 92130, France to 8 Rue Rouget de L’Isle, Issy-les-Moulineaux, 92130, France; and
Address Change of Pilatus Training Solutions Australia Pty Ltd from 81 Pearson Street, Sale, Victoria 3850 to 26-28 Wellington Park Way, Sale, Victoria 3850, Australia.

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Department of Defense, Defense Security Cooperation Agency (DSCA)

DSCA Notifies Congress of Potential FMS Sale To India

December 2, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of India has requested to buy thirty (30) Multifunctional Information Distribution System-Joint Tactical Radio Systems (MIDS-JTRS). The following non-MDE items will also be included: advanced data transfer systems; external fuel tanks; AN/AAS 44C(V) forward looking infrared (FLIR) systems; an operator machine interface assistant; spare containers; facilities study, design, construction and support; support and test equipment; munitions; integration and test support; spare and repair parts; intermediate and depot-level repair capabilities and associated spares; communications equipment; software development, delivery and support, including Joint Mission Planning System (JMPS); Identification Friend or Foe (IFF) equipment; publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services, including Navy Supply Systems Command (NAVSUP) repair capabilities and Performance Based Logistics (PBL); studies and surveys; and other related elements of logistics and program support. The estimated total program cost is $1.17 billion. The principal contractor will be Lockheed Martin Rotary and Mission Systems, located in Owego, NY. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.

https://www.dsca.mil/press-media/major-arms-sales/india-mh-60r-multi-mission-helicopter-equipment-and-follow-support

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DSCA Notifies Congress of Potential FMS Sale To Tunisia

December 3, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Tunisia has requested to buy one hundred eighty-four (184) Javelin FGM-148F missiles (includes four (4) fly-to-buy missiles); and thirty (30) Javelin Lightweight Command Launch Units (LWCLU). Also included is missile simulation round System Integration and Check out (SICO); Javelin Restricted Interactive Electronic Technical Manual (IETM); Javelin operator manual and Technical Assistance (TAGM); tools; spare parts; indoor/outdoor trainers; Javelin gunner training; Ammunition Technical Officer (ATO) training; Javelin maintenance training; and other related elements of logistics and program support. The total estimated cost is $107.7 million. The prime contractors will be the Javelin Joint Venture between Lockheed Martin, located in Orlando, FL, and RTX Corporation, located in Tucson, AZ. There are no known offset agreements in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/tunisia-javelin-missiles

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DSCA Notifies Congress of Potential FMS Sale To The Netherlands

December 6, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the Netherlands has requested to buy up to two hundred twenty-six (226) AIM-120D3 Advanced Medium Range Air-to-Air Missiles (AMRAAM); up to five (5) AIM-120D3 AMRAAM guidance sections, to include precise position provided by either Selective Availability Anti-Spoofing Module or M-Code; and one (1) AIM-120 AMRAAM Integrated Test Vehicle (ITV). The following non-MDE items will also be included: AMRAAM control sections, missile containers and support equipment; KGV-135A encryption devices; spare parts, consumables and accessories, and repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is up to $807 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor

https://www.dsca.mil/press-media/major-arms-sales/netherlands-aim-120d3-advanced-medium-range-air-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Kuwait

December 10, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Kuwait has requested to buy equipment and services required to refurbish existing maintenance facilities in Kuwait, including sustainment maintenance; special tools; repair parts; common tools; shop equipment and fixtures; materiel handling equipment; two-years of initial repair parts; bench stock; mandatory replacement materials; capability to repair small/medium arms of up to 100 mm; cables; wiring harnesses (including wiring harness manufacturing); hydraulics; fuel oil pumps; starters; generators; AGT1500 hang-on parts; functionality testing and limited repairs authorized in the technical manuals for communications equipment, fire control, night vision, and laser devices; capability to perform enhanced repairs on AGT1500 engines consistent with the TIGER Process; five years of facility operation and maintenance; field service representatives, technicians, mechanics, and other support personnel; on-the-job training; and other related elements of logistics and program support. The estimated total cost is $300 million. The principal contractors will be BAE Systems, located in York, PA; U.S. Ordnance, located in McCarran, NV; DRS Technologies, located in Arlington, VA; L3Harris Corporation, located in Tysons Corner, VA; Northrop Grumman, located in West Falls Church, VA; and RTX Corporation, located in McKinney, TX. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/kuwait-maintenance-repair-sustainment-capability

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DSCA Notifies Congress of Potential FMS Sale To Ukraine

December 10, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Ukraine has requested to buy the Joint Mission Planning System (JMPS); AN/PYQ-10 Simple Key Loaders (SKL); minor modifications and maintenance support; engine Component Improvement Program (CIP); spare and repair parts, consumables, and accessories; repair and return support; weapons software, weapons software support equipment, and classified and unclassified software and delivery support; classified and unclassified publications and documentation; personnel training and training equipment; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $266.4 million. The principal contractors will be Sabena, located in Charleroi, Belgium; Lockheed Martin Aeronautics, located in Fort Worth, TX; and Pratt and Whitney, located in East Hartford, CT. The U.S. Government is not aware of any proposed offset agreements in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/ukraine-f-16-sustainment-services

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DSCA Notifies Congress of Potential FMS Sale To The Republic of Korea

December 16, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Republic of Korea (ROK) has requested to buy modified MK 99 fire control system (FCS) cabinets; updated Weapon Direct System (WDS) software modification, integration, and installation; 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 $300 million. The principal contractors will include BAE Systems, Inc., Integrated Defense Solutions, located in Rockville, MD. Additional contractors will be determined by competition to select approved vendors. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/republic-korea-kdx-ii-class-destroyers-product-improvement-program

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DSCA Notifies Congress of Potential FMS Sale To Norway

December 17, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Norway has requested to buy eight thousand one (8,001) M1156A1 Precision Guidance Kit (PGK) multi-option fuzes that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $2.79 million, included PGK cutaway models; fuze wrenches; enhanced portable inductive artillery fuze setters; GPS antennae and cables; improved Platform Integration Kits; PGK-associated hardware for testing; labor support; training aids; technical data and reports; U.S. Government technical assistance; incidental travel; transportation; PGK spare parts; equipment training; and related elements of logistics and program support. This notification is for eight thousand one (8,001) M1156A1 PGK multi-option fuzes. The following non-MDE items will also be included: PGK cutaway models; fuze wrenches; enhanced portable inductive artillery fuze setters; GPS antennae and cables; improved Platform Integration Kits; PGK-associated hardware for testing; labor support; training aids; technical data and reports; U.S. Government technical assistance; incidental travel; transportation; PGK spare parts; equipment training; and related elements of logistics and program support. The estimated total program cost is $130 million. The principal contractor will be Northrop Grumman Innovation Systems, located in Dulles, VA. There are no known offset agreements in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/norway-m1156a1-precision-guidance-kits-fuzes

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DSCA Notifies Congress of Potential FMS Sale To Greece

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Greece has requested to buy Aerosonde Uncrewed Aircraft Systems (UAS) with Lycoming heavy-fuel engines; Global Positioning System (GPS) with Selective Availability Anti-Spoofing Module (SAASM); TASE400 Electro Optical (EO)/Medium Wave Infrared (MWIR)/Long-Range Spotter-High Definition (LRS-HD) payloads; avionics; video and telemetry datalink subsystems, and secondary payload bays; Ground Control Stations; ground data terminals; launch and recovery trailers; ground support equipment; “fly as you drive” M1117 ASV interface kits and integration; initial spares package; initial spares replenishment; new equipment training; program management support; contractor logistics support and Field Service Representative support; technical data and publications; quality assurance services; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support, that will be added to a previously implemented case whose value was under the congressional notification threshold. The principal contractor will be Textron Systems, located in Hunt Valley, MD. There are no known offset agreements in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/greece-aerosonde-uncrewed-aircraft-systems-and-armored-security

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DSCA Notifies Congress of Potential FMS Sale To the Taipei Economic and Cultural Representative Office in The United States

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Taipei Economic and Cultural Representative Office in the United States (TECRO) has requested to buy sixteen (16) MK 75 76 mm gun mounts. The following non-MDE items will be included: shipping containers; technical assistance to overhaul guns to be ready for use; and other related elements of logistics and program support. The estimated total cost is $30 million. The equipment will be purchased from U.S. stock and then overhauled to be ready for use condition by the U.S. Coast Guard. There are no known offset agreements proposed in connection with this sale.

Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to the recipient.

https://www.dsca.mil/press-media/major-arms-sales/taipei-economic-and-cultural-representative-office-united-states-mk-75

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DSCA Notifies Congress of Potential FMS Sale To the Taipei Economic and Cultural Representative Office in The United States

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Taipei Economic and Cultural Representative Office in the United States (TECRO) has requested to buy three hundred nine (309) Multifunctional Information Distribution System Joint Tactical Radio Systems (MIDS JTRS) Variant 5 (V5). The following non-MDE items will also be included: non-recurring engineering; testing, certification, and other activities necessary to integrate the MIDS JTRS V5 Block Upgrade Three on the recipient’s Patriot, HE-2K, P-3, and F-16 Block 20 platforms; communications equipment and services needed to accelerate the modernization of the recipient’s Advanced Tactical Datalink System; and other related elements of logistics and program support. The estimated total cost is $265 million. The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/taipei-economic-and-cultural-representative-office-united-states-38

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DSCA Notifies Congress of Potential FMS Sale To Egypt

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Egypt has requested a possible sale to refurbish and upgrade five hundred fifty-five (555) M1A1 Abrams tanks into M1A1SA configuration tanks. Included are five hundred fifty-five (555) AN/VAS- 5B Driver Vision Enhancer (DVE-A) Kits; five hundred fifty-five (555) Thermal Imaging System (TIS) Gunner's Sights; M250 Smoke Grenade Launchers; AGT-1500 tank engines; X-1100 tank transmissions; spare parts; support equipment; depot level support; Government-Furnished Equipment (GFE); repair parts; repair and return program; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total program cost is $4.69 billion. The M1A1SA tank contractor will be General Dynamics Land Systems, Sterling Heights, MI. Refurbishment and upgrade will take place at the Egyptian Tank Plant, Cairo, Egypt. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/egypt-abrams-tank-refurbishment-support-and-equipment

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DSCA Notifies Congress of Potential FMS Sale To Egypt

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Egypt has requested to buy an additional five hundred forty-three (543) Advanced Precision Kill Weapon Systems (APKWS) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $8 million ($5.2 million in MDE), included two hundred sixteen (216) APKWS. This notification is for a combined total of seven hundred fifty-nine (759) APKWS. The following non-MDE items will also be included: test support equipment; spare and repair parts; publications and technical documentation; personnel training and training equipment; transportation; 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 $30 million. The principal contractor will be BAE Systems, located in Nashua, NH. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/egypt-advanced-precision-kill-weapon-system-apkws

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DSCA Notifies Congress of Potential FMS Sale To Egypt

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Egypt has requested to buy two thousand one hundred eighty-three (2,183) Hellfire Air-to- Ground Missiles, AGM-114R. The following non MDE items will also be included: spare and repair parts; U.S. Government technical assistance; integrated logistics support; hardware equipment; technical publications; repair and return services; and other related elements of logistical and program support. The total estimated cost is $630 million. The principal contractor will be Lockheed Martin, located in Orlando, FL. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/egypt-hellfire-agm-114r-missiles

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DSCA Notifies Congress of Potential FMS Sale To Morocco

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Morocco has requested to buy up to thirty (30) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM) and one (1) AIM-120C-8 AMRAAM guidance section. Also included are AMRAAM telemetry kits, control section spares, and containers; Common Munitions Built-in-Test Reprogramming Equipment (CMBRE); ADU-891 Computer Test Set Adapter Groups; munitions support and support equipment; classified software delivery and support; spare parts, consumables, accessories, and repair and return support; transportation support; classified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $88.37 million. The prime contractor will be RTX Corporation located in Tucson, AZ. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/kingdom-morocco-advanced-medium-range-air-air-missiles

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DSCA Notifies Congress of Potential FMS Sale To Morocco

December 20, 2024: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Morocco has requested to buy five hundred (500) GBU-39B Small Diameter Bombs I (SDBI); and two (2) GBU-39 (T-1)/B inert practice bombs with fuze. The following non-MDE items will also be included: GBU-39 tactical training rounds; containers, weapons system support, and support and test equipment; spare parts, consumables and accessories, and repair and return support; publications and technical data; personnel training and training equipment; warranties; transportation support; site surveys; U.S. Government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $86 million. The principal contractor will be Boeing Corporation, located in St. Louis, MO. There are no known offset agreements proposed in connection with this potential sale.

https://www.dsca.mil/press-media/major-arms-sales/kingdom-morocco-gbu-39b-small-diameter-bombs-sdb-i

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

Commerce Strengthens Export Controls to Restrict China’s Capability to Produce Advanced Semiconductors for Military Applications

December 2, 2024: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a package of rules designed to further impair the People’s Republic of China’s (PRC) capability to produce advanced-node semiconductors that can be used in the next generation of advanced weapon systems and in artificial intelligence (AI) and advanced computing, which have significant military applications. This action is a proactive measure enhancing the Department of Commerce’s work to impede the PRC’s ability to procure and produce the technologies necessary for its military modernization.

The rules include new controls on 24 types of semiconductor manufacturing equipment and 3 types of software tools for developing or producing semiconductors; new controls on high-bandwidth memory (HBM); new red flag guidance to address compliance and diversion concerns; 140 Entity List additions and 14 modifications spanning PRC tool manufacturers, semiconductor fabs, and investment companies involved in advancing the PRC government’s military modernization; and several critical regulatory changes to enhance the effectiveness of our previous controls.

https://www.bis.gov/press-release/commerce-strengthens-export-controls-restrict-chinas-capability-produce-advanced

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Public Briefing on Changes to Advanced Computing and Semiconductor Manufacturing Items

December 4, 2024: 89 Fed Reg. 96095: On December 2, 2024, the Office of the Federal Register posted for public inspection two related Bureau of Industry and Security (BIS) rules: an interim final rule, “Foreign-Produced Direct Product Rule Additions, and Refinements to Controls for Advanced Computing and Semiconductor Manufacturing Items,” (RIN 0694-AJ74) and a final rule, “Additions and Modifications to the Entity List; Removals from the Validated End-User (VEU) Program” (RIN 0694-AJ77).

https://www.federalregister.gov/documents/2024/12/04/2024-28423/public-briefing-on-changes-to-advanced-computing-and-semiconductor-manufacturing-items and

https://www.federalregister.gov/documents/2024/12/04/2024-28423/public-briefing-on-changes-to-advanced-computing-and-semiconductor-manufacturing-items

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Foreign-Produced Direct Product Rule Additions, and Refinements to Controls for Advanced Computing and Semiconductor Manufacturing Items

December 5, 2024: 89 Fed. Reg. 96790: In this interim final rule (IFR), the Bureau of Industry and Security (BIS) made changes to the Export Administration Regulations (EAR) controls for certain advanced computing items, supercomputers, and semiconductor manufacturing equipment, which includes adding new controls for certain semiconductor manufacturing equipment and related items, creating new Foreign Direct Product (FDP) rules for certain commodities to impair the capability to produce “advanced-node integrated circuits” (“advanced-node ICs”) by certain destinations or entities of concern, adding new controls for certain high bandwidth memory important for advanced computing, and clarifying controls on certain software keys that allow for the use of items such as software tools. This IFR publishes concurrently with another BIS final rule entitled, “Additions and Modifications to the Entity List; and Removals from the Validated End-User (VEU) Program” (Entity List rule) that adds to and modifies the Entity List to ensure appropriate EAR controls are in place for certain critical technologies and to minimize the risk of diversion to entities of concern.

In this IFR, BIS made changes to EAR controls for advanced computing items, supercomputers, and SME. The five categories of changes implemented by this IFR are described in section III as follows:

Addition of two new FDP rules in § 734.9 of the EAR for certain types of advanced SME and for entities on the Entity List involved in the production of “advanced-node ICs”;
Additional revisions related to the production of semiconductors and other conforming changes, including revisions to de minimis provisions that correlate to the new FDP rules, establishment of new License Exception Restricted Fabrication “Facility” (RFF), addition of eight new Red Flags, clarifications to § 744.23, and revisions and conforming changes to other parts of the EAR;
Addition of HBM controls, including addition of new ECCN 3A090.c and License Exceptions HBM;
Clarification to software keys to address when authorization is required; and
Revisions to the CCL in supplement no. 1 to part 774, including revisions to eight existing ECCNs and addition of eight new ECCNs.

https://www.federalregister.gov/documents/2024/12/05/2024-28270/foreign-produced-direct-product-rule-additions-and-refinements-to-controls-for-advanced-computing and

https://www.federalregister.gov/documents/2024/12/05/2024-28270/foreign-produced-direct-product-rule-additions-and-refinements-to-controls-for-advanced-computing

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Commerce Issues Final Rule to Formalize Information and Communications Technology and Services ICTS Program

December 5, 2024: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule cementing the procedures it will follow in investigating foreign adversary threats to information and communications technology and services (ICTS) transactions that may harm U.S. national security, pursuant to Executive Order (EO) 13873: Securing the Information and Communications Technology and Services Supply Chain.

This final rule demonstrates the Biden-Harris Administration’s proactive efforts to address the potential national security risks associated with the ICTS supply chain and the abuse of U.S. critical infrastructure by foreign adversaries. It is a significant step in formalizing the operations of the Office of Information and Communications Technology and Services (OICTS), which was established within BIS in March 2022 to implement EO 13873 and related executive orders.

Since its formation, OICTS has completed or undertaken several key investigations and rulemakings. In June 2024, OICTS announced a first-of-its-kind final determination prohibiting Kaspersky Lab, Inc., the U.S. subsidiary of a Russia-based anti-virus software and cybersecurity company, from selling its software within the United States or providing updates to software already in use, amongst other activities.

Additionally, in September 2024, OICTS issued a proposed rule that would prohibit the sale or import of connected vehicles integrating specific pieces of hardware and software, or those components sold separately, with a sufficient nexus to the People’s Republic of China (PRC) or Russia. These actions underscore the critical role of OICTS in protecting American technologies and services from potentially malicious foreign adversary intervention or interference.

https://www.bis.gov/press-release/commerce-issues-final-rule-formalize-icts-program

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BIS Publishes Assessment on the Use of Mature-Node Chips

December 6, 2024: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a report on the use of mature-node semiconductor chips, or legacy chips, in supply chains that directly or indirectly support U.S. critical infrastructure. The report includes key findings related to U.S. companies’ use of legacy chips manufactured by entities based in the People’s Republic of China (PRC).

The report, based on data BIS collected pursuant to an authority under the Defense Production Act (DPA), shows:

Companies that sell products containing legacy chips continue to lack visibility into their semiconductor supply chains. About half of surveyed companies were unable to determine whether their products contained any chips manufactured by PRC-based foundries.
Based on the information respondents provided, U.S. companies’ use of chips made in PRC-based foundries is pervasive. More than 2/3 of their products contain PRC-origin chips. However, these legacy chips represent a limited share of the total number of chips used in those products.
Capacity expansion in China has already begun to cause pricing pressure that may weaken U.S. chip suppliers’ competitive positions.

https://www.bis.gov/media/documents/public-report-use-mature-node-semiconductors-december-2024 and

https://www.bis.gov/press-release/bis-publishes-assessment-use-mature-node-chips

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Implementation of Certain Australia Group Decisions

December 23, 2024: 89 Fed. Reg. 104408: The Bureau of Industry and Security (BIS) is amending the Export Administration Regulations (EAR) to implement changes agreed to by Australia Group (AG) member countries at recent meetings. These include controlling: instruments for the automated chemical synthesis of peptides (automated peptide synthesizers), dipropylamine, and neosaxitoxin; and revising the controls for botulinum toxins, toxic gas monitors, and centrifugal separators. This rule also makes minor conforming changes for the new controls and revisions to existing controls.

https://www.federalregister.gov/documents/2024/12/23/2024-30425/implementation-of-certain-australia-group-decisions

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U.S. Census Bureau

REVISION BIS LICENSE TYPE C65 – (TGL) Temporary General License

December 5, 2024

Among other actions, this interim final rule amended the existing Temporary General License (TGL) in supplement number 1 to part 736, paragraph (d), General Order number 4 of the Export Administration Regulations (EAR). General Order number 4 is amended to add newly added semiconductor manufacturing equipment (SME) ECCNs to this authorization in paragraph (d)(1)(i) and add 3A090.c under certain conditions to this authorization in paragraph (d)(2)(ii).

Revised License Code C65 (TGL)

An update has been made to AES to revise License Code C65 “Temporary General License” (TGL), which authorizes certain exports, reexports, in-country transfers, and exports from abroad destined to or within China or Macau by companies not headquartered in Country Groups D:1 or D:5 or E (see supplement no. 1 to part 740 of the EAR) to continue or engage in integration, assembly (mounting), inspection, testing, quality assurance, and distribution of items covered by ECCN 3A090.a or .b, 4A090, and associated software and technology in ECCN 3D001 (for 3A090.a or .b), 3E001 (for 3A090.a or .b), 4D090, or 4E001; or any item that is a computer, integrated circuit, “electronic assembly” or “component” and associated software and technology, specified elsewhere on Commerce Control List (supplement no. 1 to part 774), which meets or exceeds the performance parameters of ECCN 3A090.a or .b or 4A090.

Under the new interim final rule, ECCNs added to the “Less Restricted SME “parts,” “components”, or “equipment” paragraph (d)(1)(i) include 3B001.c.4, 3B993.b.1, c.2, c.3, d.4, f.2, f.3, o.2, q.1, q.2, 3B994, 3D993.a (for commodities specified in paragraph (d)(1)(i)(B)), 3D993.b through .d, 3D994, 3E993.a (for commodities specified in paragraph (d)(1)(i)(B)), 3E993.b, and 3E994.

Additionally, paragraph (d)(2)(ii) pertaining to advanced computing items is revised by adding 3A090.c when destined to or within Macau or a destination in Country Group D:5. A new paragraph, (d)(2)(ii)(B), is added to add an additional ultimate end use for 3A090.c, 3D001 (for 3A090.c), 3E001 (for 3A090.c).

The full terms of this Temporary General License are described in General Order No. 4 of in paragraph (d) in supplement no. 1 to part 736 of the EAR. See paragraph (d)(3) for item-based changes to validity dates.

AES filers must adhere to the following new reporting when using C65 (TGL) to prevent the return of fatal errors from AES:

AES filers must adhere to the following new reporting when using C65 (TGL) to prevent the return of fatal errors from AES.
Report License Code: C65 Temporary General License (TGL)
Allowable ECCNs until December 31, 2025 under General Order #4 (d)(1)(i)(A): ECCNs 3A001.z; 3A090.a and 3A090.b; 3D001 (for “software” for commodities controlled by 3A001.z, 3A090.a and 3A090.b); 3E001 (for “technology” for commodities controlled by 3A001.z, 3A090.a and .b); 4A003.z; 4A004.z; 4A005.z; 4A090; 4D001 (for “software” for commodities controlled by 4A003.z, 4A004.z, and 4A005.z); 4D090; 4E001 (for “technology” for commodities controlled by 4A003.z, 4A004.z, 4A005.z, 4A090 or “software” specified by 4D001 (for 4A003.z, 4A004.z, and 4A005.z); 4D090; 5A002.z; 5A004.z; 5A992.z; 5D002.z; 5D992.z; 5E002 (for “technology” for commodities controlled by 5A002.z or 5A004.z or “software” specified by 5D002 (for 5A002.z or 5A004.z commodities)); or 5E992 (for “technology” for commodities controlled by 5A992.z or “software” controlled by 5D992.z) of the Commerce Control List (CCL).
Allowable ECCNs until December 31, 2026 under General order #4 (d)(1): ECCN 3A991, 3B001.c.4, 3B992, 3B993.b.1, c.2, c.3, d.4, f.2, f.3, o.2, q.1, q.2, 3B994, 3D991, a (for commodities specified in this paragraph), 3D993.b through d, 3D994, 3E993.a (for commodities specified in this paragraph), 3E991, 3E993.b, or 3E994.
Allowable ECCNs until December 31, 2026 under General Order #4 (d)(2)(i)(B): 3A090.c, 3D001 (for 3A090.c), and 3E001 (for 3A090.c)

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NEW BIS LICENSE TYPE C71 – (HBM) High Bandwidth Memory

December 5, 2024:

On Monday, December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) put on public inspection at the Office of the Federal Register an interim final rule (https://www.govinfo.gov/content/pkg/FR-2024-12-05/pdf/2024-28270.pdf) with an effective date of Monday, December 2, 2024 and a compliance date of December 31 for most provisions. The IFR is expected to publish in the Federal Register on Thursday, December 5, 2024. Among other actions, this interim final rule established new controls on high-bandwidth memory units under ECCN 3A090.c, and also creates a License Exception High Bandwidth Memory (HBM) in § 740.25 of the Export Administrations Regulations (EAR), 15 C.F.R. parts 730 – 774, which can be used for certain less advanced HBM units. This license exception, as specified under § 740.25, authorizes the export, reexport, or transfer (in-country) of items specified in ECCN 3A090.c on the Commerce Control List if all terms and conditions within paragraphs (a) through (e) are met.

(in-country) If the 3A090.c items are destined for packaging at any packaging site either (i) headquartered outside of Country Group A:5 or A:6 of supplement no. 1 to part 740, or (ii) having an ultimate parent headquartered in Macau or a location specified in Country Group D:5 of supplement no. 1 to part 740, then the finished, co-packaged products must be sent back to the exporter, reexporter, or transferor for export, reexport, or transfer (in-country) to the purchaser. This allows the exporter, reexporter, or transferor to confirm that no diversion to unauthorized end-users has occurred.

For other packaging sites that face lower diversion risk, it is possible to claim License Exception HBM without needing to send the co-packaged products back to the exporter, reexporter, or transferor, if certain conditions are met (for example, the co-packaged products must not exceed the technical thresholds in ECCN3A090.

License Exception HBM under paragraph (b) specifies that the exporter, reexporter, or transferor must be headquartered in the United States or a destination specified in Country Group A:5 of supplement no. 1 to part 740, without an ultimate parent headquartered in Macau or a destination specified in Country Group D:5 of supplement no. 1 to part 740. No other exporter, reexporter, or transferor may use License Exception HBM.

3A090.c items exported, reexported, or transferred to or within Macau or a destination specified in Country Group D:5 of supplement no. 1 to part 740 must be directly purchased by the end user. 3A090.c items must be shipped directly to the packaging site, which is included to prevent diversion.

New License Code C71 (HBM)

An update has been made to AES to create new License Codes C71 “High Bandwidth Memory” (HBM) which authorizes certain export, reexport, and transfer (in-country) of items specified in ECCN 3A090.c. (in-country)

AES filers must adhere to the following new reporting when using C71 (HBM) to prevent the return of fatal errors from AES:

Report License Code: C71 Restricted Fabrication Facility (HBM)
Allowable ECCNs: 3A090.c
Allowable countries: All Countries
Allowable Export Information Codes:

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LICENSE TYPE C72 – (RFF) Restricted Fabrication Facility

December 5, 2024:

On Monday, December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) put on public inspection at the Office of the Federal Register an interim final rule (https://www.govinfo.gov/content/pkg/FR-2024-12-05/pdf/2024-28270.pdf) with an effective date of Monday, December 2, 2024 for most provisions. The IFR is expected to publish in the Federal Register on Thursday, December 5, 2024. Among other actions, this interim final rule established a new License Exception Restricted Fabrication Facility (RFF) in § 740.26 of the Export Administrations Regulations (EAR), 15 C.F.R. parts 730 - 774. This license exception as specified under the paragraph (a) (Eligibility requirements) authorizes the export, reexport, and transfer (in-country) of items not specified in ECCNs 3B001, 3B002, 3B993, 3B994, 3D992, 3D993, 3D994, 3E992, 3E993, or 3E994 to specific entities on the Entity List when § 740.26 is referenced in the Entity List “License requirement” entry.

The new License Exception RFF will allow certain items, including specified semiconductor manufacturing equipment, to be exported, reexported, exported from abroad, or transferred (in-country) to certain fabrication facilities that are subject to end user-based license requirements but that are not currently producing “advanced node ICs”.

License Exception RFF overcomes license requirements in the license requirements column of a specific entity when § 740.26 is referenced in that Entity List entry (Supplement No. 4 to Part 744 of the Export Administrations Regulations (EAR), 15 C.F.R. parts 730 – 774). This license exception does not overcome destination-based license requirements, end-use based license requirements in other sections of part 744, or license requirements that apply to other entities on the Entity List if other listed entities are a party to the transaction.

License Exception RFF may not be used for the operation, installation, maintenance, repair, overhaul, or refurbishing of commodities specified in ECCNs 3B001.a.4, c, d, f.1, f.5, k to n, p.2, p.4, r, or 3B002.c, or 3B993, or 3B994. Also, any item exported, exported from abroad, reexported, or transferred under License Exception RFF may not be used to produce “advanced-node ICs.” A notification that must be sent to BIS 45 days prior to exporting, reexporting, exporting from abroad, or transferring (in-country) that includes the end-user’s name and address, description of item(s), purchase price, and anticipated shipping date of export, reexport, or transfer (in-country).

In addition, a notification must be sent to BIS within one business day of learning that the end use has changed to “advance-node integrated circuit” “production.” There is also a reporting requirement for installation of SME that must be sent to BIS within 30 days of installation. An annual end-use confirmation report that must be sent to BIS by the exporter, reexporter, or transferor that confirms that the installed equipment is not being used in the productions of “advanced-node ICs.”

New License Code C72 (RFF)

An update has been made to AES to create new License Codes C72 “Restricted Fabrication Facility” (RFF), which authorizes certain export, reexport, and transfer (in-country) of items not specified in ECCNs 3B001, 3B002, 3B993, 3B994, 3D992, 3D993, 3D994, 3E992, 3E993, or 3E994 to specific entities on the Entity list. License Exception RFF overcomes license requirements in the license requirements column of a specific entity when § 740.26 is referenced in that Entity List entry (Supplement No. 4 to Part 744 of the Export Administrations Regulations (EAR), 15 C.F.R. parts 730 – 774). Transactions under RFF must meet all of the applicable criteria identified under paragraph (a) and must comply with the restrictions set forth in paragraph (b) of this section.

The full terms of License Exception RFF are described in § 740.26.

AES filers must adhere to the following new reporting when using C72 (RFF) to prevent the return of fatal errors from AES:

Report License Code: C72 Restricted Fabrication Facility (RFF)
Allowable ECCNs: All except 3B001, 3B002, 3B993, 3B994, 3D992, 3D993, 3D994, 3E992, 3E993, or 3E994.
Allowable countries: All
Allowable Export Information Codes: All except UG

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December 19, 2024: When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. Though the shipment is accepted, the filer may still receive a Verify Message, Compliance Alert, Informational Message or Warning Message along with their ITN. However, if the shipment is rejected, a Fatal Error notification is received and must be corrected to receive a valid ITN.

To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.

Response Code: 256

Narrative: USPPI Postal Code Not Valid for State

Severity: Fatal

Reason: The Postal Code and State Code reported in the USPPI Address do not match.

Resolution: The reported USPPI State Code must be valid for the state associated to the Postal Code.

Verify the USPPI State Code and Postal Code combination, correct the shipment and resubmit.

Response Code: 501

Narrative: Export Information Code Missing

Severity: Fatal

Reason: The Export Information Code was not reported.

Resolution: An Export Information Code must be reported on every shipment. For a complete list of Export Information Codes, refer to ‘Appendix E – Commodity Filing Export Information’ of the AESTIR.

Verify the Export Information Code, correct the shipment and resubmit.

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To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.

Response Code: 256

Narrative: USPPI Postal Code Not Valid for State

Severity: Fatal

Reason: The Postal Code and State Code reported in the USPPI Address do not match.

Resolution: The reported USPPI State Code must be valid for the state associated to the Postal Code.

Verify the USPPI State Code and Postal Code combination, correct the shipment and resubmit.

Response Code: 501

Narrative: Export Information Code Missing

Severity: Fatal

Reason: The Export Information Code was not reported.

Verify the Export Information Code, correct the shipment and resubmit.

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Changes to the Reporting Requirements of the USML Category XXI Determination Number and Goods Exported Under for Foreign Military Sales (FMS) Program in AES

December 30, 2024:

On Thursday, August 10, 2023, the Department of Commerce, U.S. Census Bureau (Census Bureau) published a final rule (2023-16970.pdf (govinfo.gov) announcing the Department of State, Directorate of Defense Trade Controls (DDTC) collection of a new data element – Category XXI Determination Number in the Automated Export System (AES).

The purpose of this requirement is to prevent the unauthorized use of USML Category XXI, which is limited to those articles and services designated by DDTC under that category.

Effective January 1, 2025, AES will generate a fatal error (FATAL ERR 5C2 CAT XXI DETERMINATION NBR UNKNOWN) back to the filer if USML Category XXI “21” is selected in AES and the CAT XXI DETERMINATION NBR is UNKNOWN or missing.

DDTC is also aware of a subset of exporters using DDTC USML Category Code “21” as a workaround to export items under License Code/License Exemption Code “S94” for Foreign Military Sales (FMS) that are not items described on the USML. Most such articles would have been subject to the Export Administration Regulations (EAR) if they were not being exported via an FMS authorization. However, effective October 15, 2013, items to be exported under FMS authority are not “subject to the EAR” pursuant to § 734.3(b)(1)(vi) of the EAR because they are “defense articles” pursuant to section 47 of the AECA (22 U.S.C. 2794).

To continue to provide a valid means of exporting such items under S94 when Fatal Error Code 5C2 takes effect, the DDTC is also implementing DDTC USML Category Code “55” and Fatal Error Code 5C3 within AES.

The Addition of USML Category Code “55”

The AES Trade Interface Requirements (AESTIR), Appendix L has been updated by adding DDTC USML Category Code “55” (Articles Exported Under Foreign Military Sales (FMS) Authority and Not Described on the U.S. Munitions List (USML)). Category Code “55” is to be reported on the EEI ONLY when the export is to take place under the FMS program and the item to be exported is not described in USML Categories I-XXI (i.e., is normally subject to the EAR when not exported pursuant to a Foreign Military Sales authorization).

See the following instructions to determine how exports under the FMS program should be reported on the EEI. Exports under the FMS program are reported under Automated Export System (AES) License Code/License Exemption Code S94. By using DDTC USML Category Code “55” and the AES License Code/License Exemption Code S94, you are certifying that the terms, provisions, and conditions of the FMS program have been met.

License Code/License Exemption Code S94 (FMS Program Exports) – Reported for any export under the FMS program. Any of the USML Category Codes are eligible with License Code/License Exemption Code S94. However, USML Category Code “55” may only be used in conjunction with License Code/License Exemption Code S94.
Export Information Codes FS and FI – these Export Information Codes are the only eligible Export Information Codes to be reported with USML Category Code “55” under License Code/License Exemption Code S94.

If the USML Category Code “55” is reported under any other license types, AES will generate a fatal error (FATAL ERR 5C3-DDTC USML CATEG 55 NOT ELIG FOR LIC TYPE) back to the filer.

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

December 3, 2024: A San Bernardino County man was arrested on a federal criminal complaint alleging that he exported to North Korea shipments of firearms, ammunition and other military items that were concealed inside shipping containers bound from Long Beach.

Shenghua Wen, 41, of Ontario, CA is charged with conspiracy to violate the International Emergency Economic Powers Act, a felony that carries a statutory maximum sentence of 20 years in federal prison.

Wen – a Chinese national illegally residing in the United States – was arrested this morning and is expected to make his initial appearance this afternoon in United States District Court in downtown Los Angeles. His arraignment is expected to occur in the coming weeks.

https://www.justice.gov/usao-cdca/pr/ontario-man-arrested-complaint-alleging-he-exported-shipments-firearms-ammunition-and

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December 3, 2024: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $14,550,000 settlement with Aiotec GmbH ("Aiotec"). Aiotec, a Berlin, Germany -headquartered company that sources industrial equipment for the energy sector, has agreed to settle its potential civil liability for one apparent violation of the Iranian Transactions and Sanctions Regulations (ITSR). This apparent violation of the ITSR arose from Aiotec's participation in a conspiracy between 2015 and 2019 to cause a U.S. company to indirectly sell and supply an Australian polypropylene plant to Iran, and remit payments for the sale of the plant through U.S. financial institutions. This settlement amount reflects OFAC's determination that Aiotec's conduct was not voluntarily self-disclosed and constituted an egregious case.

https://ofac.treasury.gov/recent-actions/20241203_33v and

https://ofac.treasury.gov/media/933666/download?inline

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December 11, 2024: A 12-count indictment was unsealed, charging Natalya Ivanovna Mazulina, of Federal Way, Washington, also known as “Natasha Mazulina,” for her alleged involvement in a scheme to circumvent U.S. export laws and sanctions on Russia. Mazulina, the Western regional manager of a freight forwarding company based in Jamaica, New York, which operated out of John F. Kennedy International Airport (JFK airport) in Queens, New York, and Seattle-Tacoma International Airport in Washington State, was arrested in Seattle and will be arraigned in the Eastern District of New York later.

Mazulina is charged with conspiracy to export controlled goods to Russia without a license, conspiracy to defraud the U.S., conspiracy to commit money laundering, exporting controlled goods to Russia without a license, filing false export documents with the U.S. government, and smuggling goods contrary to U.S. law. If convicted, she faces a maximum penalty of 20 years in prison for each count of conspiring to export or exporting controlled goods to Russia without a license; a maximum penalty of 20 years in prison for conspiring to commit money laundering; up to 10 years in prison for each count of smuggling; and a maximum penalty of five years in prison for each count of conspiracy and filing false export documents with the U.S. government. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

https://www.justice.gov/opa/pr/manager-us-freight-forwarding-company-indicted-circumventing-export-controls

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December 13, 2024: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $257,690 settlement with C.H. Robinson International Inc. (CHR). CHR agreed to settle its potential civil liability for 82 apparent violations by five of its non-U.S. subsidiaries, which provided freight brokerage or transportation services for shipments in apparent violation of OFAC sanctions on Cuba and Iran. The settlement amount reflects OFAC's determination that the apparent violations were voluntarily self-disclosed and were not egregious.

https://ofac.treasury.gov/recent-actions/20241213

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December 18, 2024: As part of a settlement agreement, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a civil penalty of $3,300,000 against Integra Technologies, Inc. (“Integra”), a radio frequency and microwave power solutions engineering and manufacturing company headquartered in El Segundo, California. The penalty relates to Integra’s shipments to Russia of transistors and related products, which can be used for avionics or radar systems. Integra made a significant number of shipments to Russia, several of which occurred after such products had been designated by the United States, the European Union, Japan, and the United Kingdom as Common High Priority List (CHPL) items. The CHPL items are items that Russia specifically seeks to procure for its defense industrial base to support weapons programs used in its full-scale invasion of Ukraine.

Integra sold approximately $6.67 million of transistors and related products, including CHPL items, to Russian end users between February 2023 and October 2023. All of these sales occurred without the requisite license or other authorization from BIS. Integra voluntarily disclosed the conduct to BIS and cooperated with the investigation by BIS’s Office of Export Enforcement. This voluntary self-disclosure (VSD) resulted in a significant reduction of the penalty. BIS also agreed to suspend $1.5 million of the penalty due to Integra’s limited ability to pay.

As part of the settlement agreement, Integra admitted to the conduct set forth in a Proposed Charging Letter, which alleged 94 violations of the Export Administration Regulations (EAR). Specifically, on 94 occasions between February 2023 and October 2023, Integra sold and exported transistors and related products via two third-party distributors to eight different Russian end users, without any license or authorization from BIS. The transistors that Integra exported were added to the CHPL in July 2023.

At the time of the violations, Integra was aware that it was shipping transistors and related products to Russian end users. However, because Integra’s export compliance program lacked procedures requiring regular review of revisions to the EAR, Integra failed to recognize that, as of February 2023, such items required a license for export to Russia. Integra did not realize its error until October 2023, after which Integra promptly stopped all shipments intended for Russian end users and filed a voluntary self-disclosure with BIS. Integra stated that, at the time of the relevant shipments, it believed the specific EAR99 products it sent to Russian end users were technologically suitable only for civil end use, rather than military end use.

https://www.bis.gov/press-release/bis-imposes-penalty-against-integra-technologies-inc-unlicensed-shipments-common-high

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December 18, 2024: Mahdi Mohammad Sadeghi, 42, a dual U.S.-Iranian national of Natick, Massachusetts, and Mohammad Abedininajafabadi, also known as Mohammad Abedini (Abedini), 38, of Tehran, Iran, have been charged with conspiring to export sophisticated electronic components from the United States to Iran in violation of U.S. export control and sanctions laws. Abedini is also charged with providing material support to a foreign terrorist organization (FTO), that resulted in the deaths of three U.S. service members who were killed by a one-way attack Unmanned Aerial Vehicle (UAV), also known as a drone, on a military base in Jordan.

Sadeghi was arrested and made his initial appearance in the District of Massachusetts. Abedini was also arrested in Italy by Italian authorities at the request of the United States.

https://www.justice.gov/opa/pr/founder-iranian-company-arrested-providing-material-support-islamic-revolutionary-guard

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December 23, 2024: The Department of Commerce’s Bureau of Industry and Security (BIS) imposed, as part of a settlement agreement, a civil penalty of $180,000 against The Indium Corporation of America (Indium), a materials refiner, smelter, manufacturer, and supplier to the global electronics, semiconductor, thin-film, and thermal management markets. Indium is headquartered in Clinton, NY.

The penalty relates to Indium’s shipments to Russia of solder materials used in electronics manufacturing valued at approximately $96,506. Indium cooperated with the investigation conducted by BIS’s Oﬃce of Export Enforcement (OEE) and took remedial measures after discovering the conduct at issue, which resulted in a signiﬁcant reduction in the penalty.

https://www.bis.gov/press-release/bis-imposes-180000-mitigated-penalty-against-indium-corporation-11-exports

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December 18, 2024: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with an individual ("U.S. Person-1"). U.S. Person-1 agreed to remit $45,179 to settle their potential civil liability for six apparent violations of OFAC's Global Magnitsky Sanctions Regulations. Between January 2021 and June 2021, U.S. Person-1 executed six payments totaling $45,179 on behalf of a blocked individual with knowledge that the individual was sanctioned. The settlement amount reflects OFAC's determination that the apparent violations were not self-disclosed and that three of the apparent violations were egregious.

OFAC also announced a settlement with Córdoba Music Group LLC (Córdoba). Córdoba, a manufacturer of musical instruments based in California, agreed to remit $41,591 to settle its potential civil liability for apparent violations of sanctions on Iran. On nine occasions, Córdoba shipped instruments and related accessories that it knew were ultimately destined for Iran. The settlement amount reflects OFAC's determination that Córdoba's conduct was non-egregious and voluntarily self-disclosed.

https://ofac.treasury.gov/media/933701/download?inline and

https://ofac.treasury.gov/media/933726/download?inline

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December 31, 2024: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $22,172 settlement with SkyGeek Logistics, Inc. (SkyGeek). SkyGeek agreed to settle its potential civil liability for six apparent violations of OFAC sanctions related to Russia’s aerospace and technology sectors. In 2024, SkyGeek attempted two refunds and sent four shipments to two Specially Designated Nationals in the United Arab Emirates sanctioned in connection with these sectors. The settlement amount reflects OFAC's determination that the apparent violations were non-egregious and that certain of its conduct was voluntarily self-disclosed.

https://ofac.treasury.gov/recent-actions/20241231_33

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Sanctions

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

December 5, 2024: 89 Fed. Reg. 96830: In this final rule, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 140 entities to the Entity List. These entries are listed on the Entity List under the destinations of China, People's Republic of (China), Japan, South Korea, and Singapore and have been determined by the U.S. Government to be acting contrary to the national security and foreign policy interests of the United States. This final rule also modifies 14 existing entries on the Entity List, consisting of revisions to 14 entries under China. This final rule publishes concurrently with BIS's interim final rule, “Foreign-Produced Direct Product Rule Additions, and Refinements to Controls for Advanced Computing and Semiconductor Manufacturing Items” (0694-AJ74), which makes additional changes to the EAR controls on advanced computing items and semiconductor manufacturing items. This final rule is part of this larger effort to ensure that appropriate EAR controls are in place on these items, including in connection with transactions destined to or otherwise involving the entities being added to the Entity List, as well as for existing entries on the Entity List that are being modified.

All of these entities (those newly added and those being modified) are involved with the development and production of “advanced-node integrated circuits” (“advanced-node ICs”) and/or semiconductor manufacturing items, and/or have supported the Chinese government's Military-Civil Fusion (MCF) Development Strategy. Additionally, this final rule designates nine of these entities being added and seven of the entries being modified as entities for which entity-specific restrictions involving foreign-produced items apply. This final rule also amends the EAR by removing three entities from the Validated End-User (VEU) Program.

https://www.federalregister.gov/documents/2024/12/05/2024-28267/additions-and-modifications-to-the-entity-list-removals-from-the-validated-end-user-veu-program and

https://www.federalregister.gov/documents/2024/12/05/2024-28267/additions-and-modifications-to-the-entity-list-removals-from-the-validated-end-user-veu-program

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December 10, 2024: 89 Fed. Reg. 99702: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 8 entities to the Entity List for activities contrary to U.S. national security and foreign policy under the destinations of the People’s Republic of China (PRC) (2), Burma (2), and Russia (4). These Entity List additions are related to enabling human rights violations.

Of the two PRC entities added, one was added because it enables human rights violations, including high-technology surveillance targeted at the general population of the people of China, Uyghurs, and members of other ethnic and religious minority groups. The other entity was added due to enabling the PRC’s public security establishment to carry out human rights violations.

Four entities, two under the destination of Burma and two under the destination of Russia, were added to the Entity List for supplying the Burmese military with parts and components that have enabled the military to carry out human rights violations, including brutal aerial attacks against the civilian population.

The remaining two Russian entities were added for supplying facial recognition technology to the Russian government to target peaceful protesters, an integral component of Russia’s mass surveillance apparatus.

Burma

Sky Aviator Company Limited; and
Synepex Shwe Company Ltd.

China

Beijing Zhongdun Security Technology Group Co., Ltd.; and
Zhejiang Uniview Technologies Co., Ltd.

Russia

Aviasnab LLC;
Joint Stock Company Gorizont;
NtechLab LLC; and
Technology Videoanalysis LLC.

https://www.federalregister.gov/documents/2024/12/11/2024-29136/additions-to-the-entity-list and

https://www.bis.gov/press-release/commerce-adds-8-entities-entity-list-enabling-human-rights-abuses

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December 30, 2024: The Department of Commerce’s Bureau of Industry and Security (BIS) published its third quarterly update of the boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business.

A party’s inclusion on the boycott Requester List does not mean that U.S. persons are restricted from dealing with the listed party. However, a party’s inclusion puts U.S. persons on notice that the listed party is more likely to make reportable boycott-related requests. The updated public list of entities who have been identified as having made a boycott-related request in reports received by BIS includes a total of 38 additions. BIS also removed over 20 entities. This announcement builds on the second quarterly update published in October.

https://www.bis.gov/press-release/bis-updates-boycott-requester-list-1

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

December 2, 2024: On the International Day for the Abolition of Slavery, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three former Government of Uzbekistan officials who were involved in human trafficking and gender-based violence, including physical and sexual violence against children at a state-run orphanage in Urgench, Uzbekistan. All three individuals are being designated pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse around the world.

Concurrently, these individuals are now subject to visa restrictions by the Department of State under Section 7031(c) of the annual Department of State, Foreign Operations, and Related Programs Appropriations Act. Section 7031(c) provides that, in cases where the Secretary of State has credible information that foreign officials have been involved in significant corruption or a gross violation of human rights, those individuals and their immediate family members are ineligible for entry into the United States.

Promoting accountability for gender-based violence is a top priority for the U.S. government. President Biden issued a Memorandum on Promoting Accountability for Conflict-Related Sexual Violence in November 2022 that directs the U.S. government to strengthen our exercise of financial, diplomatic, and legal tools against these types of abuses.

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

Khudaiberganoya, Yulduz of Uzbekistan;
Kuryazov, Anvar of Uzebekistan; and
Masharipov, Aybek of Uzbekistan.

https://ofac.treasury.gov/recent-actions/20241202 and

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

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December 3, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on 35 entities and vessels that play a critical role in transporting illicit Iranian petroleum to foreign markets. This action imposes additional costs on Iran’s petroleum sector following Iran’s attack against Israel on October 1, 2024, as well as Iran’s announced nuclear escalations, building upon the sanctions issued on October 11. Petroleum revenues provide the Iranian regime with the resources to fund its nuclear program, develop advanced drones and missiles, and provide ongoing financial and material support for the terrorist activities of its regional proxies.

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

Ceres Shipping Limited of China;
Constellation Maritime Services Limited of Liberia;
Eunomia Limited of China;
Gaffodil Co., Limited of China;
Galileos Marine Services L.L.C of the United Arab Emirates;
Inaya Ship Management Private Limited of Pakistan;
Lightship Management Ltd of the United Arab Emirates;
Lufindo Holding Limited of Seychelles;
Ocean Glory Giant Ogg SA of Panama;
Shanhai Future Ship Management Co Ltd of China;
Shanghai Legendary Ship Management Company Limited of China;
Tightship Shipping Management Private Limited of India;
Vision Ship Management LLP of India; and
Yurimaguas Ltd of the Marshall Islands.

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

Bertha (E5U5084) Crude Oil Tanker Cook Islands flag; MMSI 518999103 (vessel);
Black Panther (3EZT6) Chemical/Products Tanker Panama flag; MMSI 372988000 (vessel);
Ceres I (S9U4) Crude Oil Tanker Sao Tome and Principe flag; MMSI 668116233 (vessel);
Elva (S9A3) Crude Oil Tanker Sao Tome and Principe flag; MMSI 668116202 (vessel);
Fiona II (HPOE) Crude Oil Tanker Panama flag; MMSI 351073000 (vessel);
FT Island (HQAI6) Crude Oil Tanker Honduras flag; MMSI 334017000 (vessel);
Jaya (V7A6410) Crude Oil Tanker Marshall Islands flag; MMSI 538010982 (vessel);
Lady Lucy (5LKL2) Chemical/Products Tanker Liberia flag; MMSI 636022783 (vessel);
Lara II (3EQL7) Oil Products Tanker Panama flag; MMSI 374740000 (vessel);
Lioness (3FLM9) Chemical/Products Tanker Panama flag; MMSI 353722000 (vessel);
Masal (EPHO6) Crude Oil Tanker Iran flag; MMSI 422169700 (vessel);
Merope (3E2648) Crude Oil Tanker Panama flag; MMSI 352002495 (vessel);
Min Hang (E5U5075) Crude Oil Tanker Cook Islands flag; MMSI 518999094 (vessel);
Olive (E5U5271) Crude Oil Tanker Cook Islands flag; MMSI 518999290 (vessel);
Phonix (8RCY3) Crude Oil Tanker Guyana flag; MMSI 750308000 (vessel);
Rio Napo E5U4369) Chemical/Oil Tanker Cook Islands flag; MMSI 518998389 (vessel);
Tonil (3E2323) Crude Oil Tanker Panama flag; MMSI 352002482 (vessel);
Vanity (T7BL8) Crude Oil Tanker San Marino flag; MMSI 268241802 (vessel);
Veronica III (3E2317) Crude Oil Tanker Panama flag; MMSI 352002475 (vessel);
Vesna (V3MD7) Crude Oil Tanker Belize flag; MMSI 312242000 (vessel); and
Yuri (E5U5230) Crude Oil Tanker Cook Islands flag; MMSI 518999249 (vessel).

https://ofac.treasury.gov/recent-actions/20241203

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December 4, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five individuals and four entities that are associated with or leverage the TGR Group, a sprawling international network of businesses and employees that have facilitated significant sanctions circumvention on behalf of Russian elites. This action also identifies a Wyoming-based entity that is owned 50 percent or more by a sanctioned individual. This action continues the G7 commitment to hold accountable parties that evade or offset the impact of international sanctions, including by using digital assets, and to impose costs on illicit actors that use digital assets to enhance and transfer their wealth. These designations are the result of a collaborative effort with the United Kingdom’s (UK) National Crime Agency, the United Arab Emirates (UAE) government, the Drug Enforcement Administration, and the Financial Crimes Enforcement Network.

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

Bradens, Andrejs of the United Kingdom;
Chirkinyan, Elena of the United Kingdom;
Krasnov, Nikita Vladimirovich of Russia;
Magomedov, Khadzhi Murat Dalgatovich of Russia; and
Rossi, George of the United Kingdom.

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

Pullman Global Solutions LLC of the United States;
Siam Expert Trading Company Limited of Thailand;
TGR Corporate Concierge Ltd of the United Kingdom;
TGR DWC-LLC of the United Arab Emirates; and
TGR Partners of Russia.

https://ofac.treasury.gov/recent-actions/20241204 and

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

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December 9, 2024: On International Anti-Corruption Day, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 28 individuals and businesses involved in a global gold smuggling and money laundering network based in Zimbabwe, pursuant to Executive Order (E.O.) 13818, which targets perpetrators of serious human rights abuse and corruption around the world.

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

Abakumov, Dmytro of Ukraine;
Crosby, David Paul of the United Kingdom;
Pattni, Kamlesh Mansukhlal Damji of the United Arab Emirates;
Pattni, Mishaal Hitesh of the United Arab Emirates;
Sanjay, Raj Vaya of Zimbabwe;
Sinha, Swetang of Zimbabwe;
Sood, Rahul of India;
Vaya, Mukesh Mansukhlal of the United Arab Emirates; and
Vaya, Sanjay Keshavji of Zimbabwe.

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

Fiza Gold and Bullion Trading L.L.C of the United Arab Emirates;
Golden Luxury Jewellery Trading L.L.C of the United Arab Emirates;
Manurama Limited of Kenya;
Marwa Investments Limited of the United Arab Emirates;
Memories Golden Jewellery L.L.C of the United Arab Emirates;
Mirdk Fyuels OSOO of Krygyzstan;
Precious Bullion DMCC of the United Arab Emirates;
Royal Sona OSOO of Krygyzstan;
Rubini Investment Group Limited of the United Arab Emirates;
Ruhmeer Diamonds DMCC of the United Arab Emirates;
Sahara Petroleum OSOO of Krygyzstan;
Sakhara Petroleum OSOO of Krygyzstan;
Samaria Holdings Limited of the United Arab Emirates;
Skorus Investments PVT LTD of Zimbabwe;
Sun Multinational DMCC of the United Arab Emirates;
Sun Star Travel & Tourism L.L.C. of the United Arab Emirates;
Suprim EF IKS OSOO of Krygyzstan;
Suzan General Trading JLT of the United Arab Emirates; and
Suzan General Trading PVT LTD of Zimbabwe.

https://home.treasury.gov/news/press-releases/jy2740 and

https://ofac.treasury.gov/recent-actions/20241209

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December 10, 2024: In recognition of International Human Rights Day (IHRD), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new designations and highlighting other human rights-related sanctions actions taken over the last year. IHRD is observed annually on December 10 in commemoration of the United Nations’ adoption of the Universal Declaration of Human Rights on that day in 1948.

This action sanctions one individual and one entity involved in abuses against prisoners held in Houthi-run prisons in Yemen and one individual providing support to Bashar al-Assad. State also announced steps to impose visa restrictions on dozens of individuals pursuant to Section 212(a)(3)(C) of the Immigration and Nationality Act and designated one official under Section 7031(c) of the annual Appropriations Act for involvement in a gross violation of human rights. For more information about the State’s actions, please see their fact sheet.

The following individual was added to OFAC’s SDN List:

Abulqader Hasan Yahya, Al-Murtadha of Yemen.

The following entity was added to OFAC’s SDN List:

Houthi National Committee For Prisoners Affairs of Yemen.

https://home.treasury.gov/news/press-releases/jy2741 and

https://ofac.treasury.gov/recent-actions/20241209

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December 10, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned cybersecurity company Sichuan Silence Information Technology Company, Limited (Sichuan Silence), and one of its employees, Guan Tianfeng (Guan), both based in People’s Republic of China (PRC), for their roles in the April 2020 compromise of tens of thousands of firewalls worldwide. Many of the victims were U.S. critical infrastructure companies.

Malicious cyber actors, including those operating in China, continue to be one of the greatest and most persistent threats to U.S. national security, as highlighted in the 2024 Annual Threat Assessment released by the Office of the Director of National Intelligence.

The following individual has been added to OFAC’s SDN List:

Guan, Tianfeng of China.

The following entity has been added to OFAC’s SDN List:

Sichaun Silence Information Technology Company, Limited of China.

https://ofac.treasury.gov/recent-actions/20241210 and

https://home.treasury.gov/news/press-releases/jy2742

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December 16, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nine individuals and seven entities that have provided financial and military support to the Democratic People’s Republic of Korea (DPRK). Also, the U.S. Department of State sanctioned three targets related to the DPRK’s ballistic missile program. These actions reflect the DPRK’s escalating provocation and hostile military posturing that exacerbate global tensions and destabilize regional peace and security.

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

Choe, Chol Ryong of North Korea;
Im, Song Jin of North Korea;
Ju Chang il of North Korea;
Kim, Geum Cheol of North Korea;
Kim, Myong Jin of North Korea;
Kim, Yon Hui of China;
Kim, Yong Bok of North Korea;
Pak, Jong Chon of North Korea;
Ri, Chang Ho of North Korea;
Rim, Ryong Nam of North Korea; and
Ro Kwang Chol of North Korea.

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

DV Ink Limited Liability Company of Russia;
Golden Triangle Bank of China;
Korea Mandal Credit Bank of North Korea;
Novosibirskoblgaz Limited Liability Company of Russia;
Okryu Trading Company of China;
Second Academy of Natural Sciences Foreign Affairs Bureau of North Korea;
Sibregiongaz, AO of Russia; and
Vostok Trading Limited Liability Company of North Korea.

https://ofac.treasury.gov/recent-actions/20241216 and

https://home.treasury.gov/news/press-releases/jy2751

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December 17, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 12 individuals and eight entities, located across seven countries, who are linked to the global illicit drug trade. This action, taken pursuant to Executive Order (E.O.) 14059, underscores the United States’ commitment to combating the synthetic drug threat at home and abroad.

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

Betancourt Rosero, Camilo Esteban of Colombia;
Casarrubia Posada of Colombia;
Grinevicius, Arnas of Lithuania;
Karpavicius, Rokas of Lithuania;
Karpe, Jurga of Lithuania;
Labutis, Virginijus of Lithuania;
Leung, Ho Kai of New Zealand;
Lu, Huaying of the United Arab Emirates;
Osten Blanco, Orozman Orlando of Colombia;
Perez Castaneda, Luis Armando of Colombia;
Perrilla Sandoval, Allende of Colombia;
Staskus, Saulius of Lithuania;
Thackray, David Jonathan of Australia; and
Zhang, Jian Al Owais of the United Arab Emirates.

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

Atiya S A S of Colombia;
Dragon Secure GmbH of Switzerland;
Green Alpine Trading, LLC of the United Arab Emirates;
JT Trading Limited of New Zealand;
Karpis AG of Switzerland;
Lake Forest SP Z O O of Poland;
MB PTERA of Lithuania;
TNK Trading Limited of New Zealand; and
UAB Flavour Labs of Lithuania.

https://ofac.treasury.gov/recent-actions/20241217

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December 17, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two individuals and one entity involved in a network that launders millions of dollars of illicit funds generated by the Democratic People’s Republic of Korea (DPRK) information technology (IT) workers and cybercrime to support the DPRK Government. Based in the United Arab Emirates (UAE), Lu Huaying and Zhang Jian worked through a UAE-based front company to facilitate money laundering and cryptocurrency conversion services that funneled the illicit proceeds back to Pyongyang. This network is led by OFAC-sanctioned Sim Hyon Sop (Sim), a PRC-based banking representative for the DPRK who orchestrates money laundering schemes to fund the regime.

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

Lu, Huaying of China; and
Zhang, Jian of China.

The following entity has been added to OFAC’s SDN List:

Green Alpine Trading, LLC of the United Arab Emirates.

https://home.treasury.gov/news/press-releases/jy2752

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December 18, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two entities and two individuals for their role in developing and procuring components for sensitive navigational systems for the Iranian military. The Islamic Revolutionary Guard Corps Aerospace Force Self-Sufficiency Jihad Organization (IRGC ASF SSJO) and other Iranian organizations rely on these strategic components that are necessary for the production and proliferation of unmanned aerial vehicles (UAVs) and missiles. Concurrent with this action, the U.S. Department of State designated one individual and two entities involved in Iranian UAV and missile development. Treasury’s action was taken in coordination with the Department of Commerce and the Department of Justice, the latter of which charged and helped coordinate the arrest of one of the individuals OFAC sanctioned.

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

Abedininajafababi, Mohammad of Iran; and
Merat, Kaveh of Iran.

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

Illumove SA of Switzerland; and
Sanat Danesh Rahpuyan Aflak Company Ltd of Iran.

https://home.treasury.gov/news/press-releases/jy2755 and

https://ofac.treasury.gov/recent-actions/20241218

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December 18, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and four entities in Bosnia and Herzegovina (BiH) that form part of U.S.-designated Republika Srpska (RS) President Milorad Dodik’s (Dodik) financial network and enable the Dodik family’s continued attempts to evade sanctions. This action also targets a BiH politician who serves as a key enabler of Dodik’s corruption and destabilizing political agenda.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 1B, "Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue Service," and Russia-related General License 115 "Authorizing Transactions Involving Gazprombank Related to Civil Nuclear Energy."

GENERAL LICENSE NO. 1B: “Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue Service”

(a) All transactions and activities prohibited by Executive Order (E.O.) 14039, E.O. 14024, or the Protecting Europe’s Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA), involving Federal State Budgetary Institution Marine Rescue Service (MRS), or any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest, that are not related to the construction of the Nord Stream 2 pipeline project, the TurkStream pipeline project, or any project that is a successor to either such project, are authorized.

GENERAL LICENSE NO. 115: “Authorizing Transactions Involving Gazprombank Related to Civil Nuclear Energy”

(a) All transactions prohibited by Executive Order (E.O.) 14024 involving Gazprombank Joint Stock Company (“Gazprombank”), or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, that are related to civil nuclear energy are authorized through 12:01 a.m. eastern daylight time, June 30, 2025.

(b) For the purposes of this general license, the term “related to civil nuclear energy” means transactions undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024.

OFAC also issued one new Russia-related Frequently Asked Question (FAQ 1203).

Russia-related Frequently Asked Question 1203:

Q: What does General License (GL) 115 ("Authorizing Transactions Involving Gazprombank Related to Civil Nuclear Energy") authorize with respect to civil nuclear energy-related payments?

A: GL 115 generally authorizes all transactions involving Gazprombank Joint Stock Company ("Gazprombank"), or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, related to civil nuclear energy. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and operations initiated or under construction as of November 21, 2024: the extraction, production, refinement, conversion, enrichment, fabrication, transport, or purchase of uranium in any form; the production, generation, transmission, or exchange of nuclear power, fuel, or waste; and the operation of civil nuclear energy projects. However, GL 115 does not authorize, for instance, transactions involving Gazprombank related to the development of new civil nuclear energy power plants after November 21, 2024, or related to the Paks II nuclear power plant project, including Paks II. Nuclear Power Plant Private Limited Company (Paks II. Ltd.), or any successor project.

Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in transactions with blocked persons, including transactions related to existing civil nuclear energy as described in GL 115, where those transactions would not require a specific license if engaged in by a U.S. person.

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

Dobric, Aleksandar of Bosnia and Herzegovina;
Dobric, Mirko of Bosnia and Herzegovina; and
Kosarac, Stasa of Bosnia and Herzegovina.

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

Best Service D.O.O. of Bosnia and Herzegovina;
Nimbus Innovations D.O.O Banja Luka of Bosnia and Herzegovina;
Vorto D.O.O. of Bosnia and Herzegovina; and
Zelena Jabuka D.O.O. of Bosnia and Herzegovina.

https://ofac.treasury.gov/recent-actions/20241218 and

https://home.treasury.gov/news/press-releases/jy2756 and

https://ofac.treasury.gov/media/933721/download?inline and

https://ofac.treasury.gov/media/933706/download?inline and

https://ofac.treasury.gov/faqs/1203

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December 19, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a dozen individuals and entities based in multiple jurisdictions, including the head of the Houthi-aligned Central Bank of Yemen branch in Sana’a, for their roles in trafficking arms, laundering money, and shipping illicit Iranian petroleum for the benefit of the Houthis. Among the persons designated are key smuggling operatives, arms traffickers, and shipping and financial facilitators who have enabled the Houthis to acquire and transport an array of dual-use and weapons components, as well as generate revenue to support their destabilizing regional activities. Additionally, OFAC identified five cryptocurrency wallets associated with Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial official Sa’id al-Jamal (al-Jamal), who operates under the aliases “Khrpi,” “Ahmad Sa’idi,” and “Hisham,” among others.

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

ABD-AL-WADUD, Wail Muhmmad Said of Yemen;
Al-Hadi, Ahmad Muhammad Muhmmad Hasan of Yemen;
Al-Madani, Hashem Ismail Ali Ahmed of Yemen;
Hajj, Umar Ahmad Umar Ahamd of Yemen;
Kanniappan, JR, Ezekial of Malaysia; and
Venayagamoorthy, Puvaneswaran of Malaysia.

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

Al Hazmi Exchange Khaled Al Hazmi And Brother Company General Partnership of Yemen;
Atlantic Navigation OPC Private Limited of India;
Blu Shipping M SDN. BHD. Of Malaysia;
Brecalin Hong Kong Co Ltd of China;
Galaxy Management NV of Suriname;
Ghezel Hesar Prison of Iran; and
Journey Investment Company of the Marshall Islands.

https://ofac.treasury.gov/recent-actions/20241219 and

https://home.treasury.gov/news/press-releases/jy2757

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December 19, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Georgian officials from Georgia’s Ministry of Internal Affairs which has engaged in brutal crackdowns on media members, opposition figures, and protesters — including during demonstrations throughout 2024. These officials are being sanctioned under Executive Order (E.O.) 13818 (Global Magnitsky), following the September 16, 2024 sanctions of two other Georgian Ministry of Internal Affairs officials. This action was coordinated with the United Kingdom, which designated five individuals responsible for human rights violations in Georgia.

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

Gomelauri, Vakhtang of Georgia; and
Kezevadze, Mirza of Georgia.

https://ofac.treasury.gov/recent-actions/20241219

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December 27, 2024: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 116, "Authorizing Transactions Involving Entities Owned by Bidzina Ivanishvili." OFAC has also issued one new, Russia-related Frequently Asked Question (FAQ 1204).

GENERAL LICENSE NO. 116: “Authorizing Transactions Involving Entities Owned by Bidzina Ivanishvili”

All transactions prohibited by Executive Order (E.O.) 14024 involving any entity that is blocked solely due to a property interest of Bidzina Ivanishvili (Ivanishvili), or any entity in which Ivanishvili owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized, provided that such entity is not identified on the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons.

Russia-related Frequently Asked Question 1204

Q: On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

A: Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided that such entity is not identified on the SDN List. Non-U.S. persons may also engage in the transactions authorized by GL 116 without the risk of sanctions under E.O. 14024, as amended. However, U.S. persons are still prohibited from transacting with Ivanishvili himself unless exempt or otherwise authorized by OFAC. Additionally, as provided in paragraph (b), GL 116 does not authorize certain transactions, including transactions related to the Singapore Court of Appeal Case or related proceedings as specified in paragraph (b)(3) of the GL.

https://ofac.treasury.gov/recent-actions/20241227

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December 31, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Russian judge Olesya Mendeleeva (Mendeleeva) for her role in the arbitrary detention of Moscow city councilor and human rights defender, Alexei Gorinov. Mendeleeva is designated pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world. This action is also undertaken in the spirit of the Sergei Magnitsky Rule of Law Accountability Act of 2012 (P. L. 112-208)

The following individual has been added to OFAC’s SDN List:

Mendeleeva, Olesya Anatolevna of Russia.

https://home.treasury.gov/news/press-releases/jy2765

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December 31, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a subordinate organization of Iran’s Islamic Revolutionary Guard Corps (IRGC), and a Moscow-based affiliate organization of the Russian Main Intelligence Directorate (GRU) and its director pursuant to Executive Order (E.O.) 13848, the U.S. election interference authority. As affiliates of the IRGC and GRU, these actors aimed to stoke socio-political tensions and influence the U.S. electorate during the 2024 U.S. election. These actions build on sanctions previously imposed on the IRGC, the GRU, and their numerous subordinate and proxy organizations, pursuant to several authorities targeting the proliferation of weapons of mass destruction and malicious cyber-enabled activities.

The following individual has been added to OFAC’s SDN List:

Korovin, Valery Mikhaylovich of Russia.

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

Cognitive Design Production Center of Iran; and
International Non-Profit Foundation.

https://ofac.treasury.gov/recent-actions/20241231

DDTC Frequently Asked Questions (FAQs)

Does the term “at the company facilities” in ITAR 120.64(a)(2) include only a company headquarters, or does it also include travel to other facilities?

If a contracted employee is employed ordinarily at their company's facilities, they may also provide services for the company's clients outside the company's facilities. Such activities are within the definition of a regular employee in ITAR 120.64(a)(2).

If an item is described on the Excluded Technology List (ETL), is there any carveout that would allow it to be eligible under the ITAR § 126.7 (AUKUS) exemption?

No. If an item is described on the ETL, it is ineligible for transfer under the ITAR § 126.7 exemption.

If my commodity is not called out specifically in the EAR or the ITAR, do I need to submit a Commodity Jurisdiction Determination Request?

If you are unable to determine the classification of an item after reviewing the USML and Commerce Control List per the Order of Review (see ITAR §120.11), you may submit a commodity jurisdiction determination to DDTC.

After the expiration of a Manufacturing License Agreement (MLA) may foreign parties continue to use and exchange technical data previously authorized for export among the same foreign signatories, sub-licensees and end-users?

The continued use and exchange of the technical data previously authorized for export among the same foreign signatories, sub-licensees and end-users is generally permitted even after the agreement has terminated or expired. However, the foreign parties may not continue to use the technical data to manufacture absent separate authority. The foreign parties must seek approval from DDTC via a General Correspondence request to continue manufacturing using ITAR-controlled technical data after the expiration of an MLA. If the continued manufacturing activity requires the furnishing of a defense service by a U.S. person, then separate DDTC authorization would be required.

I have my technical data encrypted in accordance with section 120.54(a)(5) so that sending, taking, or storing it outside the United States is not considered an export, reexport, or retransfer. I understand that "access information" as defined in section 120.55 means "information that allows access to encrypted technical data . . . in an unencrypted form" and that examples include decryption keys, network access codes, and passwords. Further, I know that section 120.56(b) prohibits regulated persons from providing access information to foreign persons if the foreign persons are not otherwise authorized to receive the technical data that is encrypted. How do I determine if a violation of section 120.56(b) may have occurred?

In the case of section 120.56(b) that would be where a regulated person provided access information to a foreign person, such that the foreign person could access, view, or possess encrypted technical data in an unencrypted form through the use of that access information and the foreign person is not authorized to have the technical data.

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