ITAR UPDATES
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Consultants Corner
SYRIA UPDATE
In August 24, 2026 The Department of State rescinded Syria’s designation as a State Sponsor of Terrorism.
In a statement by Secretary Rubio ” I authorized the formal rescission of Syria’s designation as a State Sponsor of Terrorism (SST), following the conclusion of the mandatory 45-day Congressional notification period. I have also delisted Hay’at Tahrir al-Sham’s (HTS) designation as a Specially Designated Global Terrorist (SDGT). These actions represent another historic step by President Trump to give the Syrian people a path to prosperity…..This eliminates the final major barriers for private sector investment in Syria and promotes Syria’s economic recovery and reintegration into the global economy.”
Below is an overview of the current restrictions.
- OFAC
- Comprehensive sanctions targeting Syria were terminated in 6/2025.
- OFAC removed al-Nusrah Front, also known as Hay’at Tahrir al-Sham (HTS), as a Specially Designated Global Terrorist organization on 8/24/2026. HTS helped topple the Assad regime.
- OFAC removed Syria from its Sanctions Programs page
- List-based sanctions remain on Bashar al-Assad and his associates, human rights abusers, Captagon drug traffickers, and other destabilizing regional actors who remain on the Department of the Treasury’s List of Specially Designated Nationals and Blocked Persons (SDN List).
- DDTC (ITAR)
- Syria is a proscribed country under 126.1
- A regulatory amendment to the ITAR that eases exports of USML items to Syria is expected following the Secretary of State’s August 2026 waiver of the Syria Accountability Act.
- A regulatory amendment to the ITAR that eases restrictions on U.S. sales to Syria under the Arms Export Control Act, on licenses for the export to Syria of items on the USML, on U.S. foreign military financing to Syria, and on Syrian-owned or controlled air transportation to or from the United States is expected following the Secretary of State’s August 2026 waiver of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 and a 20-day notification period to Congress.
- BIS (EAR)
- BIS published a final rule on 9/2/2025 that eased restrictions on exports to Syria. The rule:
- Permits the exports and reexports of EAR99 items to Syria under license exception Syria Peace and Prosperity (SPP), provided that the transactions do not otherwise require a license based on the end-use or end-user.
- Requires export licenses for all items specified on the CCL that do not qualify for a license exception specified in 746.9.
- “ BIS will review license applications under a presumption of approval for exports and reexports of items on the CCL to Syria for commercial end uses that support economic and business development in Syria or that support the Syrian people, including through the improvement or maintenance of telecommunications, water supply and sanitation, power generation, aviation, or other civil services that support peace and prosperity in Syria without making a significant contribution to the military potential of Syria or the ability of Syria to support acts of international terrorism.”
- License Exceptions authorized under 746.9 are:
- TMP, RPL, GOV, TSU, BAF, AVS, and CCD.
- BIS published a final rule on 9/2/2025 that eased restrictions on exports to Syria. The rule:
If you have any questions, please contact us at 703-847-5801 or email us at info@fdassociates.net
UPCOMING ITAR WORKSHOPS & WEBINARS
OUR FALL SCHEDULE IS READY
Agendas available on our website
| ITAR FUNdamentals | September 29 – October 2, 2026
9 AM- 1 PM |
| ITAR for the Empowered Official | October 13, 2026
9 AM – 1 PM |
| ITAR Compliance Programs | November 3 – November 4, 2026
9 AM – 1 PM |
Drone Export Requirements Relaxed
| A Final Rule with effective August 14, 2026 has been issued by the Department of Commerce that eases export controls on certain Unmanned Aerial Vehicles (UAVs or Drones) and related parts, components, accessories, attachments, technology and software regulated under the EAR.
Specifically, ECCN 9A012 that regulated controls on UAVs/Drones is revised eliminating wind just tolerance as a parameter for determining UAVS controls and increases the control parameter for endurance to less than or greater than 3 hours. Drones with less than 3 hours of endurance, provided that they are not MT controlled based on range and payload, are exportable to most countries without a license. Drones with an endurance greater than 3 hours are NS1 controlled meaning export licenses are required except for Canada, United Kingdom and Australia. New ECCN entries are added in 9A012 to capture drones/UAVs incorporated cameras described in ECCN 6A003.b.3, 6A003.b.4.b, and radars in 6A008.d to .h. UAV and unmanned airships incorporating lasers enumerated in ECCN 6A005 and inertial measuring equipment or systems using accelerometers or gyros specified in ECCNs 7A001, 7A002, 7A003 or 7A005 are also described in the expanded ECCN 9A012. Conforming changes are made to remove national security controls on software and technology for UAVS with an endurance under 3 hours. The EAR maintains military end user/end user controls for UAVS with the lower endurance drones and their associated technology and software. To effect this change BIS has added ECCNs 9A012, 9D001, 9D002 and 9E001 to supplement no. 2 to part 744 – Items Subject to Military End Use End User Restrictions. To date UAVs have not been regulated in ECCN 9A610, based on historical aspect of military UAVs, however as UAVs have evolved with commercial UAVs being modified after development for military use, and smaller or less capable UAVs being designed and developed for military application that provide significant military advantage, but not a critical one that would warrant control in the ITAR USML. BIS identified that after interagency review it has been agreed that some military UAVs and remotely piloted vehicles can be captured in ECCN 9A610.a rather than ECCN 9A012 when “specially designed” to provide military capabilities not described on the ITAR USML. Provided as illustrative reference is Supplement No 1 to Part 744 which described “military end uses” which BIS believes is informative in assessing design or modification for military under ECCN 9A610.a including performing military reconnaissance, surveillance or combat support. The Final Rule also updates the availability for use of license exception Strategic Trade Authorization for certain transactions involving UAVs. The link to the Final Rule is HERE If you have any questions, please contact us at 703-847-5801 or info@fdassociates.net |
Drone Export Requirements Relaxed Read More »
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE AUGUST 2026
This newsletter is a listing of the latest changes in export control regulations through August 31, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
REGULATORY UPDATES
President
Continuation of the National Emergency With Respect to Export Control Regulations
August 12, 2026: 91 Fed. Reg. 53179: On August 17, 2001, the President issued Executive Order 13222 pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.). In that order, the President declared a national emergency with respect to the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States related to the expiration of the Export Administration Act of 1979, as amended (50 U.S.C. 4601 et seq.). Because the implementation of certain sanctions authorities, including sections 11A, 11B, and 11C of such Export Administration Act of 1979, consistent with section 1766(b) of Public Law 115-232, the Export Control Reform Act of 2018 (50 U.S.C. 4801 note), is to be carried out under the International Emergency Economic Powers Act, the national emergency declared on August 17, 2001, must continue in effect beyond August 17, 2026. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency declared in Executive Order 13222, as amended by Executive Order 13637 of March 8, 2013.
Note the Export Administration Act expired in 2001. The continuation of the national emergency keeps provisions of the EAA enacted.
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Rebuilding The United States Navy And America’s Shipbuilding Industrial Base
August 13, 2026: The President issued a memo directing the Department of War to restore both capacity and competition to the maritime industrial base as it expands the U.S. naval force structure. The Secretary of War, in consultation with the Secretary of Navy, shall:
- Develop a plan to replace the Electromagnetic Aircraft Launch System and Advanced Weapons Elevators with steam and hydraulic systems for the construction of CVN-81;
- Pursue more direct investments in the American shipbuilding industrial base based off of the successful “Finland model”;
- Foreign shipbuilders that make substantial and durable investments into America’s shipyards and train an all-American workforce for the jobs they create will be temporarily permitted to build up to two ships in their parent shipyards that will be delivered to bridge gaps on a quick turnaround, while additional ships will be built in revitalized American shipyards.
- Establish a fifth Naval shipyard, the first in over 80 years, to increase the Nation’s submarine and aircraft carrier repair capacity;
- Establish a Component Repair Center capable of holding, repairing, and refurbishing critical components for all current major submarine programs; and
- Undertake a full review, reform, and reorganization of Naval Sea Systems Command to address chronic challenges in American naval shipbuilding.
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Department of State, Directorate of Defense Trade Controls (DDTC)
Data Collection Modernization (DCM) Coming September 14, 2026 Modernizing DDTC’s Licensing Experience
August 5, 2026: DDTC announced the initial production release of the Data Collection Modernization (DCM) initiative, deploying to the DECCS Production environment on September 14, 2026.
The Data Collection Modernization initiative is a multi-phase effort to modernize how DDTC collects, manages, and uses data across its digital services. This initial release focuses on enhancements to the licensing experience that improve data quality, streamline application submission, and deliver a more modern, user-friendly experience for industry users.
This release affects:
- Web (UI) license submissions
- Batch license submissions
Organizations that submit applications through batch processes should ensure their systems are prepared for the September 14, 2026, production deployment.
Updated user guides will be published prior to the release.
If you have questions regarding this release, please contact the DECCS Help Desk at 202-663-2838 | DDTCCustomerService@state.gov.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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Rescission of Syria’s Designation as a State Sponsor of Terrorism
August 24, 2026: Marc Rubio, the Secretary of State, authorized the formal rescission of Syria’s designation as a State Sponsor of Terrorism (SST), following the conclusion of the mandatory 45-day Congressional notification period. The Secretary of State also delisted Hay’at Tahrir al-Sham’s (HTS) designation as a Specially Designated Global Terrorist (SDGT). These actions represent another historic step by President Trump to give the Syrian people a path to prosperity.
In the past year the Trump Administration has taken unprecedented steps to provide sanctions relief for the benefit of the Syrian people. The historic June 2025 Executive Order ‘Providing for the Revocation of Syria Sanctions’ accelerated the process of sanctions relief for Syria, including by terminating the Syria Sanctions Program and the national emergency with respect to Syria, and directing reviews on various Syria-related sanctions and terrorist designations.
These actions were all taken in recognition of the positive actions taken and further commitments by the Syrian government under President Ahmed al-Sharaa to fully distance Syria from acts of international terrorism. In the past year, the Government of Syria has taken significant steps to counter terrorism, to include formally joining the Global Coalition to Defeat ISIS in November and conducting operations to disrupt the terror networks of ISIS, al-Qa’ida, Hizballah, and Iran-aligned groups. Rescinding Syria’s designation as an SST and HTS’ designation as an SDGT eliminates the final major barriers for private sector investment in Syria and promotes Syria’s economic recovery and reintegration into the global economy.
https://www.state.gov/wp-content/uploads/2026/08/20260824-Advisory-for-Syria-State-Final-1.pdf
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International Traffic in Arms Regulations: Extension of Temporary Modification of Category XI(b) of the U.S. Munitions List
August 27, 2026: 91 Fed. Reg. 55461: DDTC placed on public inspection in the Federal Register the continuation of the temporary modification to USML Category XI(b). Originally published on July 1, 2014 (79 FR 37536), extended through August 30, 2021 (84 FR 45652) and August 30, 2026 (86 FR 48021) the Department is now extending the temporary modification until August 30, 2028.
The scope of control in existence prior to December 30, 2014 for USML Category XI paragraph (b) and directly related software in paragraph (d) remains in effect. This clarification was achieved by reinserting the words “analyze and produce information from” and by adding software to the description of items controlled in USML Category XI(b).
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Modification of Civil Aircraft to Incorporate Aircraft Survivability Equipment
August 27, 2026: 91 Fed. Reg. 55457: DDTC released an Interim Final Rule (IFR), effective October 12, 2026 that:
- Revises the U.S. Munitions List (USML) to exclude certain civil aircraft that have been modified to incorporate directed Aircraft Survivability Equipment (ASE) (USML XI(a)(4)), specifically infrared countermeasures (DIRCM) and infrared or ultraviolet missile warning systems necessary for the operation of DIRCM
- Revises the ITAR to exclude certain temporary imports and reexports of ASE from ITAR requirements, while incorporated into civil, provided specific conditions are met.
Following the effective date of the IFR, routine maintenance on an aircraft removed from the USML under this rule will no longer be subject to the ITAR defense services requirement while ASE-specific maintenance will remain a defense service. This change will facilitate timely and efficient maintenance of those aircraft by U.S. persons, including aircraft manufacturers.
DDTC is seeking public comments on this IFR for 30 days. Interested parties may submit comments by September 27, 2026, using one of the methods described in the interim final rule.
The DDTC fact sheet outlining the changes is found here:
https://deccs.pmddtc.state.gov/sys_attachment.do?sys_id=2f1a251897878fd0fe5c39b0f053af03
The IFR is found here:
https://www.federalregister.gov/d/2026-17660
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30-Day Notice of Proposed Information Collection: Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data
August 31, 2026: 91 Fed. Reg. 55966: DDTC is seeking public comments on the Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data.
In accordance with Part 123 of the International Traffic in Arms Regulations (ITAR), any person who intends to permanently export, temporarily export, or temporarily import classified defense articles, including classified technical data must first obtain Directorate of Defense Trade Controls authorization. The “Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data” (Form DSP-85) is used to obtain permission for the permanent export, temporary export, or temporary import of classified defense articles, including classified technical data, covered by the U.S. Munitions List (USML). This form is an application that, when completed and approved by the Bureau of Political Military Affairs, Directorate of Defense Trade Controls (PM/DDTC), Department of State, constitutes the official record and authorization for all classified commercial defense trade transactions, pursuant to the Arms Export Control Act and the ITAR.
DDTC is soliciting public comments to permit the Department to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
DDTC is accepting comments up to September 30, 2026.
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DDTC Name And Address Changes Posted To Website
August 1 through 31, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Australian Maritime Technologies Pty Ltd changed its name to BMT Maritime Design & Engineering Pty Ltd.
- Sopra Steria India Limited changed its addresses located at:
- Seaview Special Economic Zone Building 4, Plot No. 20 & 21, Sector – 135 Noida Gautam Buddha Nagar, U.P. 201304, India; and
- Institutional Plot No. B-9 Sector 132, Noida, 20134, India
To: Tower-A, B-9, Sector – 132 Gautam Budda Nagar Noida – 201304, Uttar Pradesh, India.
- Schenker Sp. z.o.o., a DSV entity, located at ul. Zwirki i Wigury 16C 02-092 Warszawa Poland changed its name and address to:
- DVS Road Sp. z.o.o.
- Ozarowska,nr 40/42, lok —, miejsc. Duchnice
05-850 Ozarow Mazowiecki Poland
- DVS Air & Sea Sp, z.o.o.
- Ozarowska 40/42, Duchnice
PL-05-850 Ozarow Mazowiecki, Poland
- DSV Contract Logistics Sp. z.o.o.
- Sokolowska 64
PL-05-806 Pecice Poland
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DDTC Final Commodity Jurisdiction Determinations Posted To Website
August 1, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between July 8, 2026 and July 29, 2026, on its website at:
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&kb_number=KB0011272
| Model Name | Manufacturer | Description | Final Determination | Final Determination Date |
| Nd:YAG Laser Rod (Part Number 11NY-4-46-F/F-A/A) and Nd:YAG Laser Slabs (Part Numbers 11NYSP-4.5/4.5-30-F/F-N/N and 11NYSP-4/4-30-F/F-N/N) | Laser Materials Corporation | Nd:YAG laser rod and laser slabs manufactured to customer’s size and doping specifications | USML Category XII(e)(21) | 7/8/2026 |
| Compact Embedded Network 6300/3300 Embedded Router/Switch System, CEN-9600 Series, Part Number CEN90201 | GET Engineering Corporation | Rugged tactical secure mobile network router | Seek a CCATS | 7/8/2026 |
| NLEFIA LLC Firearm Training | NLEFIA, LLC | Semi-automatic firearms training: pistol, rifle, and shotgun instruction | Seek a CCATS | 7/8/2026 |
| Switch, SP2T, Model DS0860/B1, Rev A | Daico Industries, Inc. | Radiofrequency (RF) switch for routing RF signals that operates at a frequency band from 10 to 1,000 MHz | Seek a CCATS | 7/8/2026 |
| Ultra-lightweight Modular Chassis for Schmidt-Rubin K31 Rifle; Model MC-K31-1, Version 1.0; Part Number: MC-K31-1 | Wonjin Cho | Aftermarket modular aluminum chassis/stock for bolt-action rifle | CCL ECCN 0A501.y.1 | 7/8/2026 |
| Owl XD Tyton | Owl Cyber Defense Solutions, LLC | Securely enables cloud-based iOS and iPadOS software updates for devices operating in air-gapped networks | Seek a CCATS | 7/8/2026 |
| Puncturing Cutter, Model and Part Number 1SE608 | Vectra CO. D.B.A. EaglePicher Technologies, LLC. |
Pyrotechnic-actuated cutter designed to puncture a pressurized vessel so that the stored gas can be released in a controlled fashion | Seek a CCATS | 7/8/2026 |
| Rectifiers, Model 925434-4B Rev. AW, Part No. SA8137; Model 2904394 Rev. G, Part No. SA10635; and Model 925214 Rev. K, Part No. SA10758 | Corfin Holdings Inc. | Three high-reliability rectifier assemblies used for mission-critical power electronics for specific applications | USML Category XII(e)(1) | 7/29/2026 |
| SMT Circulator X-Band, Model Number: X-Band, Part Number: 72831-G001 | TTM Technologies, Inc. | used for high performance surface-mount phased array radar antennas, electronic warfare, and communication systems | USML Category XI(c)(6) | 7/29/2026 |
| Titanium Diboride (TiB2) Advanced Ceramic Material | Leeta Materials | An advanced ceramic material composed primarily of titanium and boron | Seek a CCATS | 7/29/2026 |
| Mobile Additive Manufacturing Container (MAMC), Model MAMC v01, Part Number MAMC-001 | Sparrow Engineering, Inc. | Transportable, self-contained additive manufacturing and IT system integrating commercial 3D printers, computing, and power systems for general-purpose production in remote or infrastructure-limited environments | Seek a CCATS | 7/29/2026 |
| Roshel Senator APC/ERV Model: Senator | Roshel, LLC | Armored Ford F-550 which is capable of off-road use and has the capacity to transport 12 personnel and deploy 10 personnel | USML Category VII(e) | 7/29/2026 |
| Copper Nickel Socket Weld Pipe Union, Model and Part Number 803-6397430 Rev A | Monarch Supply Co. | 1/2″ Union, Socket Weld (S/W), 90/10 Copper Nickel (CuNi), 400# | EAR99 | 7/29/2026 |
| 515.4 Calibration Mix | Restek Corporation | reference standard used by environmental testing labs for use in instrument calibration and sample spiking for soil and water (EPA) testing | USML Category XIV(e)(1) | 7/29/2026 |
| Thin Line Towed Array Handling System (TLTAHS), Model: 1.4, Part Number: 77C965000G2, and six subassemblies | Lockheed Martin Corporation | Handling system for towed passive sonar arrays used with submarines (and six subassemblies) | USML Category XX(c) | 7/29/2026 |
| Passive Acoustic Drone Detection System | Texas International Group | Detection system based on analyzing the sound signature of drones | Seek a CCATS | 7/29/2026 |
| Chemical, Biological, Radiological, and Nuclear (CBRN) Training (CBRN Consequence Management, CBRN Awareness for First Responders, CBRN Awareness for Complex Terrorist Attack Response) |
One Thirty Nine Consulting LLC | Chemical, Biological, Radiological, and Nuclear (CBRN) Consequence Management Courses |
Not defense services | 7/29/2026 |
| UH-60 Machine Gun Mount, Part Number MAS-214 | Military Systems Group, Inc. | Machine gun mount system | USML Category I(h)(4) | 7/29/2026 |
| AtomEngine | Battle Road Digital, LLC | Planet scale modeling and simulation software | With Entity Catalog USML Category IX(b)(4)(ii)Without Entity Catalog: Seek a CCATS |
7/31/2026 |
| Gadolinium Gallium Garnet (GGG) Single-Crystal Substrates with Undoped, Single-Crystal Yttrium Iron Garnet (YIG) Film, Part Numbers MM-M2-T1-G1-D2, MM M2 T2-G1-D2, and MM-M2-T8-G1-D2 |
Metamagnetics, Inc. | Base materials that provide structure, insulation, and connective pathways for integrated circuits | Part Numbers MM-M2-T1-G1-D2 and MM M2 T2-G1-D2: USML Category XVIII(e)
Part Number MM-M2-T8-G1-D2: RWA |
7/31/2026 |
| Lidar for Situational Awareness (LiSA), Part Number 110630-0001 | Areté Associates | Lidar used for helicopter operation in clear and degraded visual environments | USML Category XII(b)(6) | 7/31/2026 |
| CSIR IP Core, Version 5.1 | STE North America, Inc. d.b.a. iDirect Government, LLC |
Communication signal interference removal software | USML Category XI(d) | 7/31/2026 |
| Mounting Plate Assembly, Model 125E3301-101 Rev 1 | USM Aerostructures, Corp. | Mounting plate assembly | CCL ECCN 9A610.x | 7/31/2026 |
| Zeeland Multi-Spectral RFI/IR Tarp, Model: Zeeland RFI/IR multipurpose Tarp Ver1.0, Part Number: 1500101132BAIR | V Technical Textiles Inc. (submitted on behalf of the OEM by Mohawk Global Trade Advisors) | Multi-purpose camouflage material designed to reduce electro-magnetic detectability across the infrared and radio-frequency ranges | USML Category XIII(j)(1) | 7/31/2026 |
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following countries, the details of which can be found at the links below:
- S. Concludes $302 Million Security Cooperation Loan to Albania, Advancing Military Modernization and Strengthening European Defense
- Norway – 155mm High Explosive (HE) M795 Projectile
- Qatar – KC-46A Aerial Refueling Aircraft
- Italy – Guidance Section Single Variant Air-to-Air Advanced Precision Kill Weapon System-II
- Norway – UH-60M Black Hawk Helicopters
- Korea – AIM-9X Sidewinder Block II Missiles
- Iraq – Bell 412 and Bell 407M Helicopters
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Department of Commerce – Bureau of Industry and Security (BIS)
DPAS Directive Allocation Order and Additional Requirements for Recoverable Critical Minerals and Materials
August 6, 2026: 91 Fed. Reg. 50701: BIS published a temporary final rule to restrict the exportation of black mass and tungsten waste and scrap without a license. Specifically, as of August 27, 2026, U.S. persons engaged in the sale of black mass and tungsten waste and scrap must allocate 100 percent of monthly sales to U.S. persons, unless an adjustment or exception is obtained in advance from BIS via a DPAS authorization. This temporary final rule applies to U.S. persons engaged in the sale of black mass (Schedule B codes 8549.13.00.00, 8549.14.00.00, and 8549.19.00.00) and tungsten waste and scrap (Schedule B code 8101.97.00.00).
This action is taken pursuant to section 101 of the Defense Production Act of 1950, as amended (‘‘DPA’’ or the ‘‘Act’’), the Defense Priorities and Allocations System (15 CFR part 700) and Presidential Determination Pursuant to Section 101 of the Defense Production Act of 1950, as Amended, on Recoverable Critical Minerals and Materials, dated July 30, 2026 (‘‘DPA Determination on Recoverable CMMs’’), in which the President authorized the Department of Commerce (‘‘Commerce’’) to address the scarcity of recoverable critical minerals and materials (‘‘CMMs’’).
BIS invites the public to submit comments on whether any additional sales requirements are necessary or appropriate to promote the national defense. Comments must be received by November 4, 2026.
https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-16078.pdf
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Streamlining Export Controls for Drone Exports
August 14, 2026: 91 Fed. Reg. 52501: BIS issued a Final Rule that eases export controls on certain Unmanned Aerial Vehicles (UAVs or Drones) and related parts, components, accessories, attachments, technology and software regulated under the EAR.
Specifically, ECCN 9A012 that regulated controls on UAVs/Drones is revised eliminating wind gust tolerance as a parameter for determining UAVS controls and increases the control parameter for endurance to less than or greater than 3 hours. (note by way of revision of this ECCN, UAVs or drones previously classified as EAR99 are lifted to this ECCN)
Drones with less than 3 hours of endurance, provided that they are not MT controlled based on range and payload, are exportable to most countries without a license.
Drones with an endurance greater than 3 hours are NS1 controlled meaning export licenses are required except for Canada, United Kingdom and Australia.
New ECCN entries are added in 9A012 to capture drones/UAVs incorporated cameras described in ECCN 6A003.b.3, 6A003.b.4.b, and radars in 6A008.d to .h.
UAV and unmanned airships incorporating lasers enumerated in ECCN 6A005 and inertial measuring equipment or systems using accelerometers or gyros specified in ECCNs 7A001, 7A002, 7A003 or 7A005 are also described in the expanded ECCN 9A012.
Conforming changes are made to remove national security controls on software and technology for UAVS with an endurance under 3 hours.
The EAR maintains military end user/end user controls for UAVS with the lower endurance drones and their associated technology and software. To effect this change BIS has added ECCNs 9A012, 9D001, 9D002 and 9E001 to Supplement No. 2 to part 744 – Items Subject to Military End Use End User Restrictions.
To date UAVs have not been regulated in ECCN 9A610, based on historical aspect of military UAVs, however as UAVs have evolved with commercial UAVs being modified after development for military use, and smaller or less capable UAVs being designed and developed for military application that provide significant military advantage, but not a critical one that would warrant control in the ITAR USML. BIS identified that after interagency review it has been agreed that some military UAVs and remotely piloted vehicles can be captured in ECCN 9A610.a rather than ECCN 9A012 when “specially designed” to provide military capabilities not described on the ITAR USML. Provided as illustrative reference is Supplement No 1 to Part 744 which described “military end uses” which BIS believes is informative in assessing design or modification for military under ECCN 9A610.a including performing military reconnaissance, surveillance or combat support.
The Final Rule also updates the availability for use of license exception Strategic Trade Authorization for certain transactions involving UAVs.
https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16628.pdf
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Streamlining Export Controls for Drone Exports – Correction
August 28, 2026: 91 Fed. Reg. 55457: BIS published a correction to its Interim Final Rule (IFR) Streamlining Export Controls for Drone Exports, 91 Fed. Reg. 52501, published on August 14, 2026.
On page 52507, in Supplement No.1 to Part 774, in the third column, on the 14th line from the top, ‘‘List of Items Controlled[MISSING]’’ should read ‘‘List of Items Controlled’’.
https://www.govinfo.gov/content/pkg/FR-2026-08-28/pdf/C1-2026-16628.pdf
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Department of War – Defense Technology Security Administration (DTSA)
Export Control License Frequently Asked Questions
August 19, 2026: DTSA posted to its website Export Control License Frequently Asked Questions (FAQs). The FAQs are at https://www.dtsa.mil/SitePages/assessing-and-managing-risk/department-of-war-export-control-license-faqs.aspx.
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Federal Communications Commission
Federal Communications Commission is Seeking Comment on Prohibiting the Importation and Marketing of Certain Foreign-Produced Military-Grade Uncrewed Aircraft Systems (UAS) and UAS Critical Components for Non-U.S. Government, Including Those With Swarming Capabilities
August 3, 2026: 91 Fed. Reg. 48870: The Federal Communications Commission (FCC) is accepting comments on proposing to prohibit the continued importation and marketing of certain military-grade foreign-made UAS and UAS critical components that are found on the FCC’s Covered List.
On December 22, 2025, the Public Safety and Homeland Security Bureau (PSHSB) added all UAS and UAS critical components produced in a foreign country to the Covered List. This action was based on a National Security Determination from an Executive Branch interagency body, including several appropriate national security agencies, determining (among other things) that UAS produced in a foreign country pose an unacceptable risk to the national security of the United States and to the safety and security of United States persons.
On August 3, 2026, PSHSB initiated another proceeding to prohibit the continued importation and marketing of foreign-produced UAS and UAS critical components that qualify as ‘‘military-grade.’’
PHSB considers military-grade UAS and UAS critical components to be any of the following:
- UAS that weigh 55 pounds or more on takeoff, i.e. UAS that are not ‘‘small unmanned aircraft’’ pursuant to Federal Aviation Administration (FAA) rules.
(2) UAS capable of dispensing ‘‘economic poison’’ under FAA rules.
(3) UAS that contain or integrate sensors capable of thermal imaging (i.e. the capability to capture and translate the difference in temperature between objects, as well as an object’s heat signature and residual heat signature).
(4) UAS that contain or integrate sensors capable of Light Detection and Ranging (LiDAR), a ‘‘remote sensing technology that measures distance by illuminating a target with a laser and analyzing the reflected light.’’
(5) UAS docking stations, defined as multipurpose systems that enable UAS to land safely, take off, recharge and/or replace batteries, and transfer data and payload.
(6) UAS ‘‘specially designed to incorporate a defense article.’’
(7) Swarming UAS, defined as:
- Ground control stations purpose- built for, or UAS integrated with flight control or vehicle management systems specially designed for, managing drone swarms, consisting of UAS that operate autonomously (without human intervention) to coordinate with each other, avoid collisions, maintain formations, and dynamically respond to changes in operational or threat environments, or if weaponized, synchronize targeting activities across multiple drones; or
- UAS purpose-built to perform flights in coordinated and synchronized formations, including applications such as multi-UAS light shows, where numerous illuminated UAS work together to create synchronized aerial displays.
This prohibition on importation and marketing would not apply to any non- military-grade UAS or UAS critical components, nor would it apply to any domestically produced UAS or UAS critical components or to any other already-authorized covered equipment. It would also only apply to covered UAS and UAS critical components and would therefore not apply to any UAS or UAS critical components that are exempt from the Covered List— including UAS and UAS critical components identified on the Defense Contract Management Agency’s (DCMA’s) Blue UAS Cleared List; UAS and UAS critical components that qualify as ‘‘domestic end products’’ under the Buy American Standard, 48 CFR 25.101(a); and UAS and UAS critical components granted a Conditional Approval by the Department of War or the Department of Homeland Security.
Comments are due to the FCC on or before September 2, 2026.
The details of the Request for Comment and interpretive explanations of “military grade” UAS and UAS critical components can be found at:
https://www.govinfo.gov/content/pkg/FR-2026-08-03/pdf/2026-15659.pdf
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
Chinese National Pleads Guilty to Trying to Obtain U.S. Military Equipment
August 10, 2026: The Department of Justice announced that Dingwei Chen, a 29-year-old citizen of the People’s Republic of China, plead guilty in federal court in Salt Lake City to violating the Arms Export Control Act. U.S. District Judge David Sam accepted Chen’s guilty plea and scheduled sentencing for Oct 19. Chen faces a maximum penalty of 20 years in prison.
Chen attempted to purchase military-grade satellite modems and radios manufactured for the U.S. military by American companies. The specific communications hardware Chen attempted to buy may not be legally exported from the United States without a license from the Department of State’s Directorate of Defense Trade Controls, which generally does not issue licenses to export military goods and services to China.
“Chen tried to divert sensitive U.S. military technologies to the People’s Republic of China, technologies the PRC could have used against us in the future,” said Assistant Attorney General for National Security John A. Eisenberg. “These advanced technologies are a product of United States ingenuity and investment, and the National Security Division will act together with our partners across the government to enforce our laws to protect the military advantage bestowed by such technologies.”
According to court records, Chen worked with others in China to try and acquire these sensitive communications systems from foreign arms dealers on the black market. They discussed various methods to export them to China. Initially, Chen and his co-conspirators sought to transship the goods through Switzerland; then they spoke about picking them up in Saipan; finally, they decided to smuggle through Mexico.
After making an initial down payment of over $40,000 U.S. dollars, Chen and his co-conspirators switched to cryptocurrency, noting that “cold wallets are essentially anonymous bank accounts. Each transaction processed through them is private and untraceable.” They went on to pay roughly $30,000 worth of USDT, which is a type of cryptocurrency. These down payments related to the purchase of 10 modems.
To avoid detection, Chen and his co-conspirators communicated using an encrypted app. Using the encrypted app, Chen claimed this was merely an initial deal, and he had funding to buy tens of millions of dollars’ worth of additional military equipment.
https://www.justice.gov/opa/pr/chinese-national-pleads-guilty-trying-obtain-us-military-equipment
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Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Rice Lake Weighing Systems, Inc.
August 12, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $60,764 settlement with Rice Lake Weighing Systems, Inc. (“Rice Lake”), a Wisconsin-based manufacturer of weighing equipment. Rice Lake agreed to settle its and its Italian subsidiary’s potential civil liability for eight apparent violations of OFAC sanctions on Iran that occurred when its Italian subsidiary, Dini Argeo S.r.l. (“Dini”), exported goods to Iran through a distributor in the United Arab Emirates (UAE) with the knowledge that these goods were ultimately destined for Iran. Specifically, between July 2019 and November 2021, Dini exported weighing equipment to a distributor located in the UAE with the knowledge that those goods would be reexported to an end-user in Iran. OFAC determined that these apparent violations were voluntarily self-disclosed and non-egregious.
https://ofac.treasury.gov/media/936706/download?inline
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U.S. Department of State Concludes $36 Million Settlement Resolving Export Violations by BAE Systems, Inc. (BAE)
August 13, 2026: BAE Systems, Inc. settled allegations that it violated the International Traffic in Arms Regulations (ITAR) in connection with unauthorized exports, retransfers of defense articles to multiple countries, including in one case to the People’s Republic of China (PRC), and unauthorized furnishing of defense services, as well as violations of applicable terms, conditions, and provisos of Directorate of Defense Trade Controls (DDTC) authorizations.
BAE agreed to pay a fine of $36,000,000 for 104 violations of the ITAR that occurred between May 2019 and March 2025 and will, among other things, appoint an independent external compliance monitor to oversee implementation of corrective actions.
The violations involved:
- Unauthorized exports of technical data related to wiring boards for use in global positioning system (GPS) receivers described in USML Category XI(c)(2), to a manufacturer located in the PRC, a destination proscribed by the ITAR;
- Unauthorized exports of technical data involving:
- Printed wiring boards (PWB) controlled under USML Category XI(c)(2) for integration into military GPS associated with an expired Manufacturing License Agreement;
- 2,4-Dinitroanisole (DNAN) explosive mixture, controlled under USML Category V(a)(11), in connection with a Request for Quote (RFQ); and
- A summary sheet of trim and stability calculations, controlled under USML Category VI(g) technical data, in connection with an RFQ;
- Unauthorized furnishing of defense services involving:
- Site acceptance testing, specialty maintenance, and operation consulting on Range Instrumentation Radars (RIR) and Electro-Optical Tracking Systems, controlled under USML Category XI(a)(3)(iv); and
- Qualification testing of support equipment controlled under USML Categories II, IV, VIII, and XI for F-16 aircraft
- Unauthorized export of a T700 Full Authority Digital Engine Control (FADEC), controlled under USML Category XIX(e), when shipping personnel mistakenly picked and shipped the FADEC as an item subject to the EAR;
- Unauthorized retransfers of a USML Category VIII(i) paint specification directly related to the F-35 Active Inceptor System defense articles when the project team transferred to the paint specification to a U.K. supplier;
- Violations of terms, conditions, and provisos of over 120 agreements dating back to 2011; and
- Violations of terms, conditions, and provisos of licenses or exemptions involving the use of 22.C.F.R 123.4(a)(1) and temporary exports under a DSP-73 license.
BAE identified in its voluntary disclosure to DDTC that the violations are the result of:
- Insufficient written policies;
- Trade compliance’s lack of experience;
- Frequent changes in export personnel that led to an ineffective transition process for managing authorizations;
- Inadequate management of agreements; and
- An insufficient IT system to track authorizations;
Details of the violations can be found at:
- https://deccs.pmddtc.state.gov/sys_attachment.do?sys_id=a3c3f9631ba60750fd4d87f4604bcbd7
- https://deccs.pmddtc.state.gov/sys_attachment.do?sys_id=9bc3b9631ba60750fd4d87f4604bcb62
- https://deccs.pmddtc.state.gov/sys_attachment.do?sys_id=dfc3f9631ba60750fd4d87f4604bcbd2
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BIS Reaches Administrative Enforcement Settlement with Plexon, Inc.
August 14, 2026: The Department of Commerce’s Bureau of Industry Security (“BIS”) released its settlement with Plexon, Inc. (“Plexon”). BIS charged Plexon with eight violations of the EAR when it made eight shipments, without a license, of its Neural Recording Data Acquisition System (“ Omniplex System”) and accessories to Academy of Military Medical Sciences (“AMMS”), a party identified on the Entity List.
The eight shipments, involving the Omniplex Systems, occurred between February 10, 2022 and August 30, 2023. Omniplex System is a machine that uses electrodes place in the brains of animals to acquire data and to identify and categorize spikes made by individual neurons in the brain. OmniPlex is classified as ECCN 4A994.k. BIS in a 2018 Advance Notice of Proposed Rule Making (ANPRM) declared brain-computer interfaces, artificial intelligence brain modeling, an other items as potential emerging technologies that could be determined essential to national security of the U.S.
AMMS was added to the Entity List on December 17, 2021 due to its use of biotechnology processes to support the Chinese military end uses and end users, including purported brain-control weaponry. The Entity List identifies parties and addresses in which a license is required for export of specified items subject to the EAR. An export to a party listed on the Entity List is prohibited.
BIS fined Plexon $1,700,000 for the eight shipments with a total value of approximately $178,721
The BIS Charging and Settlement letters are found at:
https://www.bis.gov/media/documents/plexon-inc.-8-14-2026.pdf
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BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd.
August 24, 2026: The Department of Commerce’s Bureau of Industry Security (“BIS”) released its settlement with Container Manufacturing Ltd (“Container Manufacturing”). BIS fined Container Manufacturing $1,000,000 for 10 violations of the Export Administration Regulations (“EAR”), eight involving in engaging in a prohibited activity, and two acting with knowledge of a violation. These violations occurred between March 23, 2023 and March 7, 2025 and involved the sale and export of EAR99 items with a Harmonized Tariff Schedule (“HTS”) identified on the Russian and Belarusian Industry Sector Sanctions to a Russian End User. At the time of export, commodities with a HTS on the Russian and Belarusian Industry Sector Sanctions require a BIS export license for export to Russia. The exported items had an HTS of 8466.94, 8462.29 and 4016.93 and include various parts for aluminum metalworking tools valued at $264,721.
On February 24, 2022, BIS implemented broad export controls on Russia. As part of those controls, effective March 3, 2022, BIS imposed an additional license requirement for exports, reexports, and transfers (in-country) to or within Russia of any items subject to the EAR if identified under certain HTS codes. The March 2022 rule also added Supplement No. 4 to Part 746—HTS Codes that require a license for export, reexport, and transfer (in-country) to or within Russia—which identified HTS codes subject to the license requirement then set forth in paragraph § 746.5(a)(1)(ii).
Between March 23, 2023 and March 7, 2025 Container Manufacturing made 8 shipments without the required licenses from BIS to an unnamed Russian company identified as Company 1 in which it had a longstanding relationship. Four of these shipments involved transshipments through a third country distributor Company 2 located in the U.A.E.
BIS charged Container Manufacturing with two instances of acting with knowledge of a violation when it proceeded with shipments to Company 1 that transshipped through a distributor, Company 3 located in Turkey, after Container Manufacturing was informed by its bank that the dealings with Company 1 may be subject to U.S. legal restrictions. In a December 26, 2024 email to COMPANY 1, Container Manufacturing communicated that it had “received notification from the bank that the two pending wire payments will NOT be processed due to the embargo on Russia.”
BIS stated in its charging letter the bank notice “presented a red flag that Container Manufacturing should have resolved or justified before proceeding with further exports to COMPANY 1.” Rather than contacting the bank for clarification or seeking clarification from outside counsel to resolve the red flag, Container Manufacturing had Company 1 reissue the bank transfer under the name of one of Company 1’s business partners to evade the bank’s screening process.
Container Manufacturing subsequently transshipped the items through Turkey and misrepresented the Turkish distributor, Company 3, on the Shipper’s Letter of Instruction as the Ultimate Consignee and “Direct Consumer.” Prior SLIs involving Company 3 had identified the company as a “Reseller.”
Container Manufacturing, despite the red flags presented by the bank and instructions from Company 1 to alter transaction structure to obfuscate its role in the transaction, proceeded with the shipments in violation of the EAR.
The Charging and Settlement Letters are found at:
https://www.bis.gov/media/documents/container-manufacturing-ltd-8-24-2026.pdf
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Arms Dealer Sentenced to Prison for Conspiring to Export American Made Ammunition Used in War Against Ukraine
August 24, 2026: The Department of Justice, Eastern District of New York, sentenced Manfred Gruber, an Italian national, to 18 months in prison for conspiracy to commit export control violations. Gruber pleaded guilty to the charge on March 30, 2026.
The defendant, Manfred Gruber, was the Director of Sales for Italian Company-1, a large wholesale distributor of firearms and ammunition. The defendant served as a key member of an international procurement network for Russia during its war against Ukraine, purchasing ammunition from the United States and reexporting it to Kyrgyzstan in violation of DOC licenses issued to Italian Company-1, which required that the ammunition stay in Italy. The defendant did not apply for, obtain, or possess a license to export or reexport ammunition to Kyrgyzstan.
The defendant illegally exported ammunition worth over $540,000 from the United States to Kyrgyzstan, via companies that the defendant and his co-conspirator controlled in Italy. After reaching Kyrgyzstan, most of this ammunition was subsequently reexported to Russia.
In one example of the defendant’s illegal transactions, U.S. Company-1, headquartered in Nebraska, had a license to lawfully export ammunition to Italian Company-1, but the ammunition could not be reexported out of Italy. In violation of the license, the defendant, using a cutout company, Italian Company‑2, reexported U.S. Company-1 ammunition to Sergei Zharnovnikov, an arms dealer from Kyrgyzstan who has since pleaded guilty to conspiracy to violate export controls by sending U.S.-made firearms and ammunition to Russia. A contract found on Zharnovnikov’s phone indicated that he had contracted with a Russian company for ammunition manufactured by U.S. Company-1. Zharnovnikov was sentenced to 39 months’ imprisonment earlier this year. See United States v. Zharnovnikov, 25‑cr‑45 (HG).
In addition, U.S. Company-2, headquartered in Tennessee, had a license to lawfully export ammunition to Italian Company‑1, but the ammunition could not be reexported out of Italy. The defendant exported the ammunition from U.S. Company-2 to Italy, and then reexported the U.S. Company-2 ammunition from Italy to Kyrgyzstan.
The defendant was aware that U.S. law prohibited the reexport of U.S. ammunition without further licenses, which he did not obtain. To help the unlawful export scheme succeed, the defendant took steps to disguise the true destination of the ammunition. For example, in encrypted messages on or about September 23, 2023, the defendant and a co-conspirator discussed splitting up a shipment of 100,000 bullets. In the defendant’s words, this was necessary “so it goes unnoticed” by “FBI.”
“The defendant was held accountable for his scheme to send military‑grade ammunition to Kyrgyzstan before reexporting the ammunition to Russia to support its war effort,” stated United States Attorney Nocella. “Today’s sentencing reaffirms that people who illegally divert weapons will be brought to justice.”
“Manfred Gruber’s guilty plea reflects our unwavering commitment to enforcing U.S. export-control laws and protecting national security. His actions undermined federal regulations designed to safeguard our defense materials, and this outcome demonstrates that violations of these laws will be addressed with the utmost seriousness,” stated FBI Assistant Director in Charge Barnacle.
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Florida Firearms Parts Dealer Pleads Guilty to Exporting Weapons Components as Part of Russia-Based Scheme
August 25, 2026: Maxim Larin pleaded guilty in federal court in Brooklyn, NY to conspiracy to violate the Export Control Reform Act and attempting to violate the Arms Export Control Act in connection with his shipment of weapons parts and accessories to Kazakhstan. The proceeding was held before United States District Judge Nina R. Morrison. When sentenced, the defendant faces a maximum sentence of 40 years’ imprisonment. As part of his plea, the defendant agreed to forfeit $250,000 and dozens of weapons parts and accessories seized from his residence.
“Motivated by greed, the defendant placed his own self-interest above the safety and security of our country and its allies by shipping export-controlled weapons parts to a volatile area of the world,” stated United States Attorney Nocella. “Today’s guilty plea should serve as a warning to all who seek to evade our nation’s export regulations for their own gain and for the benefit of our adversaries. Our Office and our law enforcement partners will vigorously investigate, prosecute, and hold to account those who compromise our national security.”
Larin is the owner of several U.S. based companies which deal in weapons parts and sensitive firearms accessories. Larin used his businesses to sell export-controlled weapons parts and accessories to his co-defendant based in Russia. The items Larin shipped to Kazakhstan were on the Commerce Control List (“CCL”) and designated as export restricted because their reshipment could be detrimental to U.S. foreign policy or national security.
As early as December 2022, Larin agreed with his Russia-based co-defendant to undervalue and mislabel the contents of the packages he was exporting. When asked by his co-defendant to falsely label the contents of a specific parcel, Larin replied “we can do that.” U.S. Customs and Border Protection records show the package was mislabeled and the value of its contents was listed as thousands of dollars less than its actual value. Larin also flagged for his co-defendant that certain items could be seized by U.S. authorities and suggested that items be repackaged to make them less conspicuous.
In approximately May 2023, Larin agreed with his co-defendant to ship semi-automatic enhanced triggers, hi-speed triggers, and charging handles to Kazakhstan. These items, which enhance the performance of firearms, were all included on the CCL and their export to Kazakhstan was prohibited. Larin suggested the items could be seized by U.S. authorities and agreed to falsely declare the contents of the package and its value. Rather than state that the parcel contained firearms parts, Larin listed its contents as a “light switch.”
In December 2023, Larin agreed to acquire a Raptar target acquisition device for his co-defendant. The Raptar is a firearms accessory which helps users acquire targets at long ranges. Given its obvious military application, the Raptar is included on the United States Munitions List, a list of items which cannot be exported from the United States without the approval of the Directorate of Defense Trade Controls, a unit within the U.S. Department of State. Larin obtained the Raptar device from another company and signed an agreement which specified that the item could not be shipped internationally. Although he knew about this prohibition, Larin shipped the Raptar to a co-conspirator in the United States who attempted to ship it to Kazakhstan in violation of U.S. export laws. The device was intercepted and seized by HSI in California.
Larin was arrested in Florida in August 2025.
Note: The supplier’s notice to Larin that the Raptar device couldn’t be shipped abroad was both a best practice and protected the U.S. seller and was a bonus for law enforcement.
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Russian National Living in Florida Convicted for Scheme to Illegally Export Aircraft Parts from the United States to Russia
August 28, 2026: A Florida resident and Russian national, Alexander Mamonov, 62, was convicted on all charges following a jury trial related to a scheme to illegally export aircraft parts from the United States to Russia and the state-owned Russian airline, PJSC Aeroflot.
“This guilty verdict – on all counts – shows the United States government’s resolute commitment to upholding our export-control laws and to prosecuting those who violate them,” said Assistant Attorney General for National Security John A. Eisenberg. “The National Security Division and our U.S. Attorney’s Offices and law enforcement partners will continue to safeguard U.S.-controlled items from being exported unlawfully.”
“Mamonov illegally exported nearly one million dollars of aviation parts to Russia by lying to U.S. suppliers about their destination, and this conviction on all counts holds him accountable,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “The FBI and its partners will continue to prioritize the enforcement of export laws and sanctions to defend the homeland. Let this verdict serve as a warning to anyone considering smuggling U.S. technology to our adversaries.”
“Russia cannot evade American sanctions and export controls by routing its purchases through South Florida,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “You cannot put a fake destination on a shipping label and make American export laws disappear. This defendant conspired to secretly funnel nearly $1 million in American aircraft parts to Russia and Aeroflot, then used false destinations and financial transactions to conceal what he was doing. Yesterday, a federal jury held him accountable on every count. We will continue to aggressively pursue those who use our district, our financial system, or American businesses to undermine U.S. national security.”
Mamonov was convicted in the Southern District of Florida of 12 counts related to that scheme, including conspiracy to violate the Export Control Reform Act (ECRA), illegal export of items subject to ECRA, conspiracy to commit smuggling, smuggling of goods, submitting false or misleading export information, and conspiracy to commit money laundering. U.S. District Court Judge Kathleen M. Williams scheduled sentencing for Nov. 20.
The defendant was charged by indictment in April 2025, alongside Ignat Vakorin of Russia. Vakorin remains a fugitive in wanted status.
Following Russia’s further invasion of Ukraine in early 2022, the U.S. Department of Commerce increased restrictions on exports to Russia and issued a temporary denial order barring Aeroflot from receiving U.S.-origin goods. According to court documents and testimony, Mamonov is a former Aeroflot employee who relocated from Russia to South Florida. After the U.S. Department of Commerce increased restrictions on Russian exports, Mamonov conspired with Vakorin to acquire and illegally ship over $900,000 in aircraft parts to Russia and to Aeroflot. Mamonov and Vakorin misled U.S. suppliers into believing the parts were being sent to other destinations, such as the United Arab Emirates and China.
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BIS Investigates Apex Logistics over Nvidia Servers: First Freight Forwarder Targeted
August 28, 2026: According to the Tech Times, the Commerce Department’s Bureau of Industry and Security is “examining whether Singapore-based Apex Logistics — a wholly owned subsidiary of Swiss shipping giant Kuehne+Nagel — transported Nvidia AI server hardware to China in violation of US export restrictions, in what would mark the first-ever enforcement action against a transportation company for participating in the illegal semiconductor trade.” The investigation involves 47 shipments containing an unknown number of Nvidia servers.
As noted in the article, BIS has put freight forwarders on “written notice” and has published “Freight Forwarder Guidance and Best Practices on its website found at: https://www.bis.gov/learn-support/export-compliance-programs/freight-forwarder-guidance.
The complete article is found at:
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Ohio State University Agrees to $2.1M Settlement to Resolve Allegations that it Failed to Disclose Employees’ Ties to the People’s Republic of China in Applications for Federal Research Funding
August 31, 2026: Ohio State University (OSU), a public university in Columbus, Ohio, has agreed to pay a total of $2,100,000 to resolve civil allegations that it failed to disclose OSU employees’ affiliations with and support from the People’s Republic of China (PRC) in connection with federal research funding.
“American universities that benefit from the federal government’s support for scientific research and advancement must fully disclose all foreign funding in their grant applications,” said Assistant Attorney General Brett A. Shumate of the Justice Department’s Civil Division. “We will continue to hold accountable any university that fails to comply with disclosure requirements designed to protect research security and federally-funded scientific achievements.”
“Together with the Department of Justice and National Aeronautics and Space Administration (NASA), we have secured a major financial recovery on behalf of the American public,” said Robert Steinau, Senior Official at the NASA Office of Inspector General. “The settlement and accompanying compliance agreement send a clear message: We will not tolerate institutions that conceal foreign ties and compromise national security. Our cutting-edge research must not fall into the hands of our adversaries.”
This settlement relates to NASA and National Science Foundation (NSF) grants that provided funding to OSU from November 2012 to August 2023. In the funding application process, NASA and NSF required OSU to disclose, among other things, foreign government support received by any principal investigator (PI) or co-PI on the grant application. Further, since 2011, federal law prohibits the use of grant funds for collaborations with the PRC, PRC Universities, or any PRC-owned companies. The settlement resolves allegations that OSU failed to disclose the collaboration and affiliation with, or funding received from, the PRC by certain OSU employees working on NASA and NSF grants.
Specifically, the settlement resolves allegations that since 2014, annual Faculty Activity Reports submitted to OSU identified affiliations with PRC universities and state-run research organizations, but OSU did not disclose this information to NASA or NSF. In addition, OSU learned in 2019 that a Principal Investigator (PI) on NASA grants was a participant in a Thousand Talents Program, a program established by the PRC to recruit individuals with knowledge or access to foreign technology intellectual property, but OSU did not notify NASA or NSF until four years later in 2023. The United States identified additional OSU employees who worked on those grants and were affiliated with, or collaborated with, or received funding from, the PRC.
https://www.justice.gov/opa/media/1459616/dl
Sanctions
Department of State
Imposition of Nonproliferation Measures Against Foreign Persons, Including a Ban on U.S. Government Procurement
August, 4, 2026: 91 Fed. Reg. 49481: The Department of State made a determination that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to the Iran, North Korea, and Syria Nonproliferation Act (INKSNA). The measures when into effect on July 24, 2026.
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Department of Commerce – Bureau of Industry and Security
Removal From the Entity List
August 24, 2026: 91 Fed. Reg. 54657: The Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) by removing Atempo Proje Taahhut Ses ve Goruntu Sistemleri Anonim Sirketi Istanbul Subesi, Bulent Ecevit Bulvar in Turkey from the Entity List)
https://www.govinfo.gov/content/pkg/FR-2026-08-24/pdf/2026-17230.pdf
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Revisions to the Entity List
August 24, 2026: 91 Fed. Reg. 54658: Bureau of Industry and Security (BIS) revises the Export Administration Regulations (EAR) by removing two addresses associated with Arrow Electronics (Hong Kong) Co., Ltd. from the Entity List under the destination of China, People’s Republic of (China).
https://www.govinfo.gov/content/pkg/FR-2026-08-24/pdf/2026-17231.pdf
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for August 1 through August 30, 2026.
- Issuance of Amended Venezuela-related General License and Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260803
- Counter Terrorism Designations Removals and Update
https://ofac.treasury.gov/recent-actions/20260805
- Targeting Enablers of the Cuban Regime’s Arms Imports and Foreign Military Cooperation
- Cuba-related Designations; Issuance of Cuba-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260806
- Counter Terrorism and Iran-related Designations; Counter Narcotics Designations Removals; Issuance of Amended Iran-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260807
- Advancing the United States’ Campaign to Address the Threat Posed by the International Criminal Court
- https://www.state.gov/releases/office-of-the-spokesperson/2026/08/advancing-the-united-states-campaign-to-address-the-threat-posed-by-the-international-criminal-court/
- International Criminal Court-related Designations; Venezuela-related Designation; Issuance of International Criminal Court-related General License
https://ofac.treasury.gov/recent-actions/20260818
- Treasury Sanctions Major Ecuador-Based Cocaine Network Linked to Violent Gangs and Mexican Cartels
https://home.treasury.gov/news/press-releases/sb0610
- Treasury Increases Sanctions on Hizballah and Targets Network Smuggling Millions in Cash for Hizballah
https://home.treasury.gov/news/press-releases/sb0611
- Imposing Sanctions on Cuban Regime Actors Associated with Marxist Subversive Networks and Corrupt Economic Dealings
- Counter Narcotics, Counter Terrorism, Cuba-related, and Iran-related Designations; Issuance of Russia-related General License; Issuance of Associated Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260820
- Issuance of Venezuela-related General Licenses and Associated Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260821
- Treasury Launches Unprecedented Campaign Against Iranian Regime on Economic D-Day
https://home.treasury.gov/news/press-releases/sb0613/
- United States Implements Operation Economic Outcast with Sanctions Targeting Iran’s Military Activities and Procurements, and Petroleum and Petrochemical Product Traders
- Treasury and State Departments Deliver Additional Sanctions Relief on Syria
https://home.treasury.gov/news/press-releases/sb0612/
- Removal of Syria’s designation as a State Sponsor of Terrorism and Associated Sanctions List Updates; Iran-related Designations; Updates to Iran-related General Licenses
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE AUGUST 2026 Read More »
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE JULY 2026
This newsletter is a listing of the latest changes in export control regulations through July 31, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
Securing America’s Defense Supply Chains And Ensuring Domestic Acquisition Of Critical Materials
July 20, 2026: 91 Fed. Reg. 14415: The President issued Executive Order (EO) 14415 to strengthen U.S. defense supply chains. It is the policy of the United States that not only the finished equipment deployed by our military, but also the critical materials and components necessary to manufacture, maintain, sustain, and repair that equipment, are sourced domestically or from allied nations.
The EO:
- Restricts the use of waivers that allow defense contractors and sub-contractors to source materials from U.S. adversaries.
- Authorizes the use of a waiver when a contractor submits a formal mitigation plan that identifies:
- The source of the non-compliant material;
- Documents evidencing exhaustive efforts made to acquire material from a compliant source;
- Steps to be taken by the contractor to remove the non-compliant material from its supply chain; and
- A timeline for completing the mitigation plan.
- Requires the Secretary of War to develop policy and implementation guidance to require all prime contractors and subcontractors at any tier to map and illuminate critical supply chains for all Department of War acquisitions that support, implicate, or relate to United States national security. The proposed regulations shall include requirements that:
(i) Contractors must submit to the Department of War a complete indentured Bill of Materials that traces all components, parts, equipment, software, and materials back to the origin of raw materials in their supply chains;
(ii) Contractors must establish and implement written procedures, in accordance with existing Department of War procedures for conducting supply chain risk assessments, to proactively vet all suppliers and subcontractors that support the critical supply chain; such vetting for critical supply chains shall, at a minimum, include screening of subcontractors and suppliers for the following categories of supply chain risks and challenges:
(A) financial, as defined in section 7(c) of this EO,
(B) foreign ownership, control, or influence, as defined in section 7(d) of this EO, and
(C) manufacturing and supply, as defined in section 7(e) of this EO;
(iii) Prohibit contractors from utilizing in their supply chains covered material supplied by an unreliable foreign supplier, as defined in section 7(f) of this EO; and
(iv) Contractors to track and report: vetting activities; significant supply chain risks; and mitigation activities until closure.
Details of the EO can be found at the following links.
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Department of State
Imposition of Additional Sanctions on Sudan Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991
July 20, 2026 :91 Fed. Reg. 45309: On June 23, 2026 the Under Secretary of State for Arms Control and International Security decided to impose additional sanctions on Sudan. As a result, the following additional sanctions are hereby imposed:
- Multilateral Development Bank Assistance: The United States Government shall oppose, in accordance with Section 701 of the International Financial Institutions Act (22 U.S.C. 262d), the extension of any loan or financial or technical assistance to Sudan.
The Under Secretary of State 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 on loans or financial or technical assistance to Sudan that serve the basic human needs of its citizens.
- Further Export Restrictions: The authorities of section 6 of the Export Administration Act of 1979 shall be used to prohibit exports to Sudan of all other goods and technology (excluding food and other agricultural commodities and products).
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 with respect to items not on the Commerce Control List (CCL). The restrictions are also partially waived in order to allow the authorization of exports or re-exports of goods or technology on the Commerce Control List (CCL) to Sudan in the following categories:
License Exceptions: Exports and re-exports of goods or technology on the CCL may be authorized under License Exceptions CCD, GOV, ENC, BAG, TMP, RPL, TSU and ACE, as described in 15 CFR part 740.
Safety of Flight: Exports and re-exports of goods or technology on the CCL 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 on the CCL 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 goods or technology on the CCL may be authorized pursuant to new licenses for exports and re-exports to wholly-owned subsidiaries of U.S. and foreign companies in Sudan, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
Licenses for all other exports, reexports, or transfers (in-country) of items on the CCL to Sudan will be reviewed under a “presumption of denial.”
National security-sensitive goods and technology exports to Sudan remain subject to the sanctions under section 307(a)(5) of the Act as described in the June 27, 2025 Federal Register notice. Consistent with the above, all other licenses for the export, reexport, and transfer (in-country) of national security-sensitive goods and technology will be reviewed under a “presumption of denial.”
- Action Regarding Aviation: The Department of Transportation shall take all steps necessary to suspend the authority of foreign air carriers owned or controlled by the Government of Sudan to engage in foreign air transportation to or from the United States.
This notice is effective on July 20, 2026.
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Department of State, Directorate of Defense Trade Controls (DDTC)
30-Day Notice of Proposed Information Collection: Disclosure of Violations of the Arms Export Control Act
July 1, 2026: 91 Fed. Reg. 40085: The Directorate of Defense Trade Controls (DDTC) is soliciting public comments to permit the evaluation of a form for the submission of voluntary disclosures. DDTC will accept comments up to July 31, 2026.
DDTC encourages voluntary disclosures of violations of the Arms Export Control Act (AECA) its implementing regulations, the International Traffic in Arms Regulations (ITAR), and any regulation, order, license, or other authorization issued thereunder. The information disclosed is analyzed by DDTC to ultimately determine whether to take administrative action concerning any violation that may have occurred. Voluntary disclosures may be considered a mitigating factor in determining the administrative penalties, if any, that may be imposed. Failure to report a violation may result in circumstances detrimental to U.S. national security and foreign policy interests and will be an adverse factor in determining the appropriate disposition of such violations. Also, the activity in question might merit referral to the Department of Justice for consideration of whether criminal prosecution is warranted. In such cases, DDTC will notify the Department of Justice of the voluntary nature of the disclosure, but the Department of Justice is not required to give that fact any weight.
ITAR § 127.12 describes the information which should accompany a voluntary disclosure. Historically, respondents to this information collection submitted their disclosures to DDTC in writing via hard copy documentation. However, as part of an IT modernization project designed to streamline the collection and use of information by DDTC, a discrete form has been developed for the submission of voluntary disclosures. This will allow both DDTC and respondents submitting a disclosure to more easily track submissions.
DDTC is soliciting public comments to permit the DDTC to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
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30-Day Notice of Proposed Information Collection: Brokering Approval (License)
July 7, 2026: 91 Fed. Reg. 41725: The Directorate of Defense Trade Controls (DDTC) is soliciting public comments to permit the evaluation of information collected in connection with brokering. DDTC will accept comments up to August 6, 2026.
In accordance with part 129 of the ITAR, U.S. and foreign persons who wish to engage in ITAR-controlled brokering activity of defense articles and defense services must first register with DDTC. Brokers must then submit a written request for approval to DDTC and receive DDTC’s approval prior to engaging in such activities, unless exempted. This information is currently used in the review of the brokering request submitted for approval and to ensure compliance with defense trade statutes and regulations. It is also used to monitor and control the transfer of sensitive U.S. technology.
Applicants may submit a Brokering Approval Request electronically via DDTC’s Defense Export Control and Compliance System (DECCS), using the DS-4294.
DDTC is soliciting public comments to permit the Department to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
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U.S. Department of State Issues a Press Release Regarding the Issuance of an Interim Final Rule to Eliminate Burdensome Regulations on Firearms Suppressors
July 22, 2026: In support of the President’s Executive Order on Reforming Foreign Defense Sales to Improve Speed and Accountability, the Department has issued an interim final rule that will remove certain firearm silencers, mufflers, and sound suppressors from the International Traffic in Arms Regulations (ITAR)’s U.S. Munitions List (USML). The export of these items will be controlled by the Department of Commerce’s Bureau of Industry and Security (BIS). This action eliminates unnecessary and burdensome regulations and aligns export controls on suppressors with the controls already applied to firearms.
This action eliminates unnecessary regulations and aligns export controls on suppressors with the standard controls already applied to firearms. In doing so, this proposed rule further enables U.S. industry to compete in the global marketplace with foreign producers of these broadly available technologies and supports the continued use of these technologies in international recreational firearm activities.
The changes will take effect November 20, 2026. Public comments on this interim final rule, posted to the Federal Register, will be accepted for 30 days, until August 24, 2026.
- The Department’s Directorate of Defense Trade Controls (DDTC) is continually working to benefit U.S. industry by helping American manufacturers compete in foreign markets alongside their foreign competitors.
- In consultation with its interagency partners, the Department assesses that firearm silencers, mufflers, and suppressors, other than those specially designed for fully automatic firearms, no longer provide a critical military or intelligence advantage, consistent with ITAR § 120.3 and Executive Order 14268.
- Under this rule, certain suppressors and other similar items will be added to the Commerce Control List (CCL), and BIS will require a license for certain exports, reexports, or in-country transfers of the newly controlled suppressors, including releases of related software and technology to foreign persons. License exceptions currently available for firearms will also be available for suppressors.
- These changes will have no effect on the possession, sale, or import of these items under the Department of Justice’s Bureau of Alcohol, Tobacco, and Firearms’ regulations.
- Silencers, mufflers, and sound suppressors specially designed for fully automatic firearms and fully automatic shotguns remain on the USML and will continue to be subject to Department controls under the ITAR.
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Removal from the U.S. Munitions List of Silencers, Mufflers, and Sound Suppressors for Non-Automatic and Semi-Automatic Firearms
July 22, 2026: 91 Fed. Reg. 46279: DDTC published an interim final rule removing silencers, mufflers, and sound suppressors for non-automatic and semi-automatic firearms up to .50 caliber from the International Traffic in Arms Regulations’ U.S. Munitions List (USML). A complementary rule by the Department of Commerce’s Bureau of Industry and Security will add these items to the Commerce Control List. Silencers, mufflers, and sound suppressors specially designed for fully automatic firearms up to .50 caliber and fully automatic shotguns will remain on the USML.
This rule is in furtherance of the President’s April 9, 2025, Executive Order 14268, “Reforming Foreign Defense Sales to Improve Speed and Accountability,” which directed the review of the USML to ensure that its control scope focused “on our most sensitive and sophisticated technologies.” The Department assessed that these items no longer provide a critical military or intelligence advantage.
This rule will take effect on November 20, 2026. The Department is seeking public comments on this rule for 30 days. Interested parties may submit comments by August 24, 2026 using one of the methods described in the interim final rule.
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U.S. Department of State Debars 14 Persons for Violating or Conspiring to Violate the Arms Export Control Act
July 27, 2026: 91 Fed. Reg. 46821: DDTC announced the debarment of 14 persons for violating or conspiring to violate the Arms Export Control Act. Under the terms of the statutory debarment, these persons are prohibited from participating directly or indirectly in any activities that are subject to the ITAR. Each person on this list will remain debarred until the Department approves an application request for reinstatement. All persons engaged in activities subject to the ITAR should be vigilant in their compliance with all export control regulations and ensure that their activities do not involve debarred persons.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=237f3595975e47500083b3b0f053afa9
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International Traffic in Arms Regulations: Modification of Civil Aircraft to Incorporate Aircraft Survivability Equipment.
July 27, 2026: DDTC is preparing to publish an interim final rule to amend the International Traffic in Arms Regulations (ITAR) to remove from the U.S. Munitions List (USML) items that no longer warrant inclusion and to exclude from the ITAR certain requirements for reexports, retransfers, and temporary imports.
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=1400-AG17
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International Traffic in Arms Regulations: Clarifying Policies of Denial, Updating the Major Non-NATO Ally List, and Minor Corrections
July 28, 2026: DDTC sent a final rule for interagency review that will amend the International Traffic in Arms Regulations (ITAR) to clarify certain policy-of-denial provisions, update country policies for Ethiopia, Iraq, and Somalia, add Saudi Arabia and Peru to the list of major non-NATO allies, and make minor, miscellaneous corrections.
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=1400-AG31
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30-Day Notice of Proposed Information Collection: Annual Brokering Report
July 29, 2026: 91 Fed. Reg. 47914: The Directorate of Defense Trade Controls (DDTC) is soliciting public comments to permit the evaluation of information collected in connection with the annual brokering report. DDTC will accept comments up to August 28, 2026.
In accordance with part 129 of the ITAR, U.S. and foreign persons required to register as a broker shall provide annually a report to DDTC enumerating and describing brokering activities, including all persons who participated in the activities, the quantity, description, and U.S. dollar value of the defense articles or defense services, the type and U.S. dollar value and source of any consideration received, and the DDTC number for the approval or the exemptions claimed. This information is currently used in the review of munitions export and brokering license applications and to ensure compliance with defense trade statutes and regulations. As appropriate, such information may be shared with other U.S. Government entities.
Brokering Reports are submitted annually with Statement of Registration renewals.
DDTC is soliciting public comments to permit the Department to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
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DDTC Name And Address Changes Posted To Website
July 1 through July 31, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Honeywell International Inc. spun off its Aerospace business to become a separate entity as follows:
- Previous Parent Entity: Honeywell International Inc. 855 S. Mint Street Charlotte, NC 28202, United States
New Parent Entity: Honeywell Aerospace Inc. 1944 E. Sky Harbor Circle, Phoenix, AZ 85034, United States
- Previous US Trading Name: Honeywell Aerospace Technologies 855 S. Mint Street Charlotte, NC 28202, United States
New U.S. Operating Company: Honeywell Aerospace US LLC 1944 E. Sky Harbor Circle, Phoenix, AZ 85034, United States
- Ultra PCS Limited and Ultra Electronics CEMS Limited changed their address as follows:
- From: Ultra PCS Limited Arle Court, Hatherley Lane Cheltenham, GL51 6PN
To: Ultra PCS Limited & Ultra Electronics CEMS Limited Brook Road Wimborne Dorset, BH21 2BJ United Kingdom
- From: Ultra Electronics CEMS Limited Waverley House, Hampshire Rd., Granby Industrial Estate Weymouth, DT4 9XD
To: Ultra PCS Limited & Ultra Electronics CEMS Limited Brook Road Wimborne Dorset, BH21 2BJ United Kingdom
- Aciturri Aeronáutica, S.L. and its subsidiaries changed its legal names as follows:
- Aciturri Aeronáutica, S.L. to Sonaca España Aeronáutica, S.L.
- Aciturri Aerostructures, S.L.U. to Sonaca Espana Aerostructures, S.L.U.
- Alestis Aerospace, S.L.U. to Sonaca Espana Aerospace, S.L.U.
- Aciturri Engineering, S.L.U. to Sonaca Espana Engineering, S.L.U.
- Goodrich Actuation Systems SAS changed its name to Safran Actuation Systems France
- Goodrich Actuation Systems Limited changed its name to Safran Actuation Systems Uk Ltd.
- Capella Space Corporation, 438 Shotwell Street, San Francisco, CA 94110 changed its address to 397 S Taylor Avenue, Louisville, CO 80027
- Spirent Communication PLC changed its name to Keysight Technologies (Spirent Service) Limited as a result of an acquisition.
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DDTC Final Commodity Jurisdiction Determinations Posted To Website
July 1, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between June 1, 2026 and June 30, 2026, on its website at:
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&kb_number=KB0011272
| Model Name | Manufacturer | Description | Final Determination | Final Determination Date |
| Skydio R10 Drone Part Numbers DR5E2KT2VR00000US (Two Drone Kit) and DR5ESKT2VR00000US (Single Drone Kit) and the Skydio C38 Controller, Part Number DR4ECTR200G0000JP | Skydio, Inc. | Compact quadcopter unmanned aerial vehicles (UAVs), and a wireless UAV controller | Seek a CCATS | 6/1/2026 |
| Collar, Part Number 20550467 | Lockheed Martin Corporation | Strain relief collar for a connector | USML Category XII(e)(1) | 6/1/2026 |
| SHARK Sensor Hub, Model SH 100 | Rugged Logic, Inc. | Ruggedized edge AI computing system | USML Category XI(b) | 6/1/2026 |
| Air-Breathing Ramjet Missile Mockup. Model 400B-010_Missile Cross-Team, Part Number 1727546 | Oerlikon AM US Inc. | Non-specific mockup used to demonstrate additive manufacturing applications | Seek a CCATS | 6/4/2026 |
| MAD Fuel System, Model: MAD-01 | Air Company Holdings, Inc. dba: AIRCO | A containerized fuel synthesis platform capable of producing JP-8, Jet A, and diesel fuel | Seek a CCATS | 6/4/2026 |
| Wolf Talk | Trident Systems LLC | An audio bridging and intercom system | Seek a CCATS | 6/4/2026 |
| Technical Proposal for Autonomous Aeriel Robotic Platform, as submitted | Artemis Smart Solutions LLC | Technical Proposal for an integrated printed circuit board | EAR99 | 6/4/2026 |
| HYT-172-00510 Piston Actuator | Riverbend Energetics MFG, LLC | Pyrotechnic-actuated piston | USML Category III(d)(11) | 6/9/2026 |
| Precision Wound Optical Cable Spools, Part Numbers 7090-2-2.8-5.6, 7053-2-3.75-5.2, 7034-2-4-5, 7260-4-8-9.5, and 7495-4-12.6-9.5 | Linden Photonics, Inc. | Packs of optical cable that deploy by being pulled from the inside end | Seek a CCATS | 6/15/2026 |
| Aspis Rucksack, Models Aspis 3 and Aspis 5 | System Technologies | Backpacks for small unmanned aerial vehicles | Seek a CCATS | 6/15/2026 |
| Advanced Battle Management Service | Monterey Technologies, Inc. | Proposed services in support of NATO’s Alliance Federated Surveillance and Control (AFSC) program | USML Category XI(d) | 6/23/2026 |
| Terrain Intelligence Engine (TIE) v1.0 | Aetherion Robotics LLC | Prototype system for predicting terrain conditions for autonomous platforms | Seek a CCATS | 6/23/2026 |
| .30-06 Springfield Blank Ammunition, Part Number OO-3006-BLK-1 | Orlando Ordnance, LLC | .30-06 Blank Ammunition | CCL ECCN 0A505.d | 6/23/2026 |
| M8, Model and Part Number: NFE004 | NFE Tactical LLC | reusable smoke grenade head | Seek a CCATS | 6/23/2026 |
| Simple Interface for GPS Health and Tracking (SIGHT), Model and Part Number SGTV2-XX | Navigation Technology Associates, Inc. | GPS receiver display | Seek a CCATS | 6/30/2026 |
| Flexible Coupling per AS7512, Model Number: 32J10, Part Number: 32J10-24A | Hydraflow | Fuel system coupling | Seek a CCATS | 6/30/2026 |
| DEW002 | Tactical Laser Defense Systems, Inc. | Handheld class IIIb laser designed to emit a controlled, expanded beam pattern for causing temporary optical interference with camera sensors | USML Category XVIII(a) | 6/30/2026 |
| Dagger Enterprise, Version 4.14.0 | The Johns Hopkins University – Applied Physics Lab | Suite of software applications | Dagger Service v4.14.0 – USML Category IX(b)(4)(iii) Dagger Application v4.14.0 – USML Category IX(e)(1) Dagger Web Application v.15.7 – USML Category IX(e)(1) | 6/30/2026 |
| Incident Response Diode (IRD), Model IRD 1.0 | Owl Cyber Defense Solutions, LLC | USB device that provides a security barrier between a computer and an untrusted device during data transfer | Seek a CCATS | 6/30/2026 |
| StratoDrop, Model SD-10 v2 | In Orbit Aerospace Inc. | High Altitude unmanned aerial system that uses a paraglider for lift and guidance | Seek a CCATS | 6/30/2026 |
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
- Kingdom of Saudi Arabia – Advanced Precision Kill Weapon Systems
- Kuwait – C-17 Sustainment
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/07/kuwait-c-17-sustainment/
- Greece – Switchblade 300 Block 20 Lethal Miniature Aerial Missile System
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Department of Commerce – Bureau of Industry and Security
Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations
July 10, 2026: 91 Fed. Reg. 43034: The Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will significantly upgrade the status of the United Arab Emirates (UAE) under the Export Administration Regulations (EAR) (15 CFR parts 730-774) in recognition of the UAE’s status as a U.S. Major Defense Partner and its support in advancing U.S. national security interests, including Operation Epic Fury.
BIS removed the UAE from EAR Country Groups D:3 and D:4, which among other things, eliminated restrictions on support for the UAE’s unmanned aerial vehicle programs. At the same time, BIS reclassified the UAE as EAR Country Group A:5. This provides the UAE Government and approved commercial entities with eligibility for license-free exports, reexports, and in-country transfers under License Exception Strategic Trade Authorization (STA) of Commerce-controlled military items; certain commercial satellites and spacecraft; and dual-use items useful in oil and gas production, desalination, civil nuclear power generation, and/or other items available to Country Group A:5 destinations license-free. License-free exports, reexports, and in-country transfers of these items under STA will support key UAE commercial and infrastructure needs and better equip the UAE defense establishment to support U.S. interests in the Middle East. This special status under the EAR is warranted in light of the ongoing U.S.-UAE military partnership and the UAE’s commitment to preventing the diversion and misuse of sensitive U.S. technology.
In addition, consistent with the U.S.-UAE Artificial Intelligence Cooperation framework signed in May 2025, Commerce is approving the UAE Government and certain companies to receive advanced computing items in the UAE license-free, including AI chips and servers. The UAE has reaffirmed its commitment to the investment commitments in the framework, including the commitment to make matching investments in U.S. AI digital infrastructure buildout.
https://www.bis.gov/press-release/department-commerce-eases-export-controls-uae
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Implementation of EAR Export Controls on Silencers, Mufflers, and Sound Suppressors; and Other Firearms Related Changes
July 22, 2026: 91 Fed. Reg, 46252: BIS published an Interim Final Rule (IFR) alongside the complementary State IFR implementing State’s removal of certain sound suppressors for firearms and shotguns from the USML under the ITAR. As specified in the IFR, the sound suppressors removed from the USML by the State IFR will be controlled on the CCL and enumerated under new item paragraph 0A501.f in ECCN 0A501 and item paragraph 0A502.f in ECCN 0A502. Items controlled under ECCN 0A501.f are sound suppressors capable of being used with rifles controlled under ECCNs 0A501 or 0A506, pistols controlled under ECCNs 0A501 or 0A507, or certain sound suppressors capable of being used interchangeably with any combination of rifles, pistols, and shotguns. Sound suppressors that are for exclusive use with shotguns controlled under ECCNs 0A502 or 0A508 are enumerated under ECCN 0A502.f. BIS has also moved the items formerly identified in the header of ECCN 0A502 into item paragraphs within the ECCN.
BIS will require an authorization to export, reexport, or transfer (in-country) sound suppressors that are being added to the CCL, including releases of related technology and software controlled on the CCL, to foreign persons in the United States or abroad.
This rule is effective November 20, 2026, except for amendatory instructions 1, 2, 3, 4, 6, 7, 8, 9, 10, and 11, which are effective July 23, 2026. Details of the IFR can be found at the following link.
https://www.govinfo.gov/content/pkg/FR-2026-07-23/pdf/2026-14942.pdf
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Department of Commerce Issues a Press Release re Streamlining Export Controls for Sound Suppressors
July 27, 2026: BIS announced that, as of November 20, 2026, the export of certain silencers, mufflers, and sound suppressors is subject to BIS’s Export Administration Regulations, rather than the State Departments U.S. Munitions List. This deregulatory action aligns export controls on suppressors with the controls already applied to firearms.
Under this rule, suppressors will be added to the Commerce Control List (CCL), and BIS will require a license for certain exports, reexports, or in-country transfers of the newly controlled suppressors, including releases of related software and technology to foreign persons. License exceptions currently available for firearms will also be available for suppressors.
“This deregulatory action on suppressors is a common-sense move that alleviates the compliance burden on America’s proud firearms industry, while continuing to protect national security,” said Jeffrey I. Kessler, Under Secretary of Commerce for Industry and Security.
issued a press release
https://www.bis.gov/press-release/department-commerce-streamlines-export-controls-sound-suppressors
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
Massachusetts Man Convicted of Violating U.S. Sanctions Against Iran
July 14, 2026: A Massachusetts man was convicted in federal court in Boston following a 14-day jury trial for charges related to a scheme to illegally export sophisticated electronic components from the United States to Iran.
Mahdi Mohammad Sadeghi, 43, a dual U.S.-Iranian national of Natick, Massachusetts, was convicted of one count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR); and two counts of violation of the IEEPA and the ITSR.
The defendant was charged by criminal complaint in December 2024 alongside Mohammad Abedininajafabadi, also known as Mohammad Abedini (Abedini), of Tehran, Iran, and subsequently indicted by a federal grand jury shortly thereafter. They were again charged in a superseding indictment in December 2025. Abedini remains a fugitive in wanted status.
Abedini is the founder and managing director of an Iranian company, San’at Danesh Rahpooyan Aflak Co. (SDRA or SADRA), that manufactures navigation modules used in the IRGC’s military drone program. SDRA’s main business is the sale of a proprietary navigation system—known as the Sepehr Navigation System—to the IRGC, which the United States designated as a foreign terrorist organization (FTO) on April 15, 2019. The primary application of SDRA’s Sepehr Navigation System is for use in Unmanned Aerial Vehicle (UAVs) – also known as drones – as well as cruise and ballistic missiles.
Sadeghi was employed by a Massachusetts-based microelectronics manufacturer (U.S. Company 1) and was one of the founders of a Massachusetts-based technology company (U.S. Company 2) that specializes in wearable sensors that provide kinetic monitoring for fitness applications.
Sadeghi and, allegedly, Abedini and others conspired to evade U.S. export control and sanctions laws by procuring U.S. origin goods from, U.S. Company 1 and causing them to be exported and supplied to Iran and, in particular, Abedini’s Iranian company, SDRA.
In or around 2016, Sadeghi traveled to Iran to request funding for U.S. Company 2 from the Iranian National Elites Foundation (INEF), which is an Iranian governmental organization whose main purpose is to recognize, organize and support Iran’s elite national talents. In exchange for funding for U.S. Company 2, which Sadeghi’s company ultimately received from the INEF, Sadeghi and others created a second company in Iran (Iranian Company 1). Shortly after forming Iranian Company 1, Sadeghi, through Iranian Company 1, entered into a contract with SDRA for the purchase of SDRA’s technology. On multiple occasions beginning in or around 2016, Sadeghi helped Abedini procure U.S. export-controlled electronic components for reexport to Iran.
Due to U.S. laws restricting exports to Iran, Abedini established a Switzerland front company for SDRA, Illumove SA (Illumove). According to court documents, with Sadeghi’s assistance, Abedini, through Illumove, entered into a contract with U.S. Company 1 to develop a product to evaluate U.S. Company 1’s electronic components, including sophisticated semiconductors. Sadeghi caused U.S.-origin goods to be transferred to Iran, through Illumove, for the benefit of SDRA, including accelerometers, gyroscopes, and inertial measurement units. Certain of the electronic components that Abedini allegedly obtained through Illumove were the same types of electronic components used in SDRA’s Sepehr Navigation System.
Abedini also allegedly provided material support to a foreign terrorist organization, the IRGC Aerospace Force, which is a strategic missile, air and space force. Since at least in or about 2014, SDRA has had multiple projects with the IRGC Aerospace Force, including projects for guided rockets and integrated navigation systems. As alleged, between 2021 and 2022, approximately 99% of SDRA’s sales of the Sepehr Navigation System, which are used in IRGC one-way attack drones, were to the IRGC’s Aerospace Force.
“By illegally exporting sophisticated American technology to Iran, Sadeghi violated U.S. laws and endangered national security,” said Assistant Director Roman Rozhavsky of the FBI Counterintelligence and Espionage Division. “This conviction holds him accountable. The FBI and our partners are committed to using all our resources to bring to justice anyone who helps our adversaries.”
On Jan. 28, 2024, three U.S. service members were killed, and more than 40 others were injured, in a drone attack by IRGC-backed militants on a military base located in northern Jordan, known as Tower 22. According to court documents, analysis of the drone that was recovered from the site of the attack showed that the drone was an Iranian Shahed UAV and that the navigation system used in the drone was manufactured by Abedini’s company.
The charges of violation of the IEEPA and the ITSR, and conspiracy to do so, each provide for a sentence of up to 20 years in prison, three years of supervised release and a fine of up to $1 million fine. Sentences are imposed by a federal district court judge based upon the U.S. Sentencing Guidelines and statutes which govern the determination of a sentence in a criminal case.
https://www.justice.gov/opa/pr/massachusetts-man-convicted-violating-us-sanctions-against-iran
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The Boeing Company Settles Antiboycott Violations
July 31, 2026: The Office of Antiboycott Compliance (OAC), the Bureau of Industry and Security (BIS) published the settlement agreement with The Boeing Company (Boeing) for violations of the anti-boycott provisions of the Export Administration Regulations. Boeing agreed to pay a civil penalty of $41,000 for two violations of the regulations.
Boeing voluntarily disclosed to OAC two incidents that occurred in October and November of 2019 involving the company’s intent to comply with, further, or support an unsanctioned foreign boycott, furnished two items of information concerning Boeing’s or another person’s past, present or proposed business relationships with or in a boycotted country or with another person who is known or believed to be restricted from having any business relationship with or in a boycotting country.
In 2019, Boeing furnished to a U.S. trade show logistics provider two items of information in combined commercial invoices/packing lists concerning Boeing’s past, present or proposed business relationships with or in a boycotted country or with another person who is known or believed to be restricted from having any business relationship with or in a boycotting country in violation of 15 C.F.R. § 760.2(d).
Specifically, Boeing participated in the Dubai Airshow in the United Arab Emirates in November 2019. In connection with temporary exports of Boeing models and office supplies for the air show, a Boeing employee downloaded from a U.S. trade show logistics provider’s website (and subsequently completed on behalf of Boeing) a combined commercial invoice/packing list template containing the following prohibited boycott language:
- “We certify that no labor, capital, parts or raw materials of Israeli origin have been used in the printing, publishing or manufacture of these goods and [that] none are part or parent companies of firms included on the Israeli Boycott Blacklist…”; and
- “[We certify that] none are part or parent companies of firms included on the Israeli boycott blacklist.”
The proposed charging letter, the order and settlement agreement are found at:
https://www.bis.gov/media/documents/a781.pdf
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for July 1 through July 31, 2026.
- Counter Narcotics Designations; Counter Terrorism Designations and Designation Update
https://ofac.treasury.gov/recent-actions/20260701
- Treasury Sanctions Brazilian Criminal Network Exploiting U.S. Financial System to Launder Drug Proceeds
https://home.treasury.gov/news/press-releases/sb0549
- Terrorist Designation of Chone Killers
- Reminder to File the 2026 Annual Report of Blocked Property
https://ofac.treasury.gov/recent-actions/20260701_33
- Issuance of Amended Iran-related General License
https://ofac.treasury.gov/recent-actions/20260707
- Issuance of Amended Russia-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260708
- Issuance of Democratic Republic of the Congo-related General License
https://ofac.treasury.gov/recent-actions/20260710
- Iran-related and Counter Terrorism Designations; Issuance of Iran-related General License
https://ofac.treasury.gov/recent-actions/20260710_33
- Treasury Targets Key Supreme Leader Financier and Iran’s Shadow Exchange Houses
https://home.treasury.gov/news/press-releases/sb0558
- Cyber-related Designations; Cuba Designations; Issuance of Cuba-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260713
- Treasury Sanctions Malware and Infrastructure Providers Supporting Ransomware Attacks Against Americans
https://home.treasury.gov/news/press-releases/sb0559
- Further Sanctions on the Cuban Regime’s Sources of Funding and Tools of Oppression
- Non-Proliferation Designations; Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260715
- Treasury Targets Global Network Procuring Weapons for Iranian Regime
https://home.treasury.gov/news/press-releases/sb0564
- Hong Kong-related Designations Updates and Removals
https://ofac.treasury.gov/recent-actions/20260717
- Issuance of Venezuela-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260717_33
- Russia-related Designations Updates
https://ofac.treasury.gov/recent-actions/20260720
- Counter Terrorism Designations; Counter Narcotics Designations; Cuba Designations; Belarus-related Designation Removal; Issuance of Cuba-related General Licenses
https://ofac.treasury.gov/recent-actions/20260723
- Treasury Disrupts Muslim Brotherhood and Hamas Financial Networks
https://home.treasury.gov/news/press-releases/sb0572
- Treasury Takes Largest Action Ever Targeting Cartel de Jalisco Nueva Generacion
https://home.treasury.gov/news/press-releases/sb0573
- Additional Sanctions Designations Targeting the Corrupt Cuban Communist Regime and its Financial Backers
- Iran-related Designations; Issuance of Amended Russia-related General License and Frequently Asked Questions; Issuance of Amended Venezuela-related Frequently Asked Question; Publication of Regulatory Amendments
https://ofac.treasury.gov/recent-actions/20260724
- Sanctions List Removals; Sanctions List Updates
https://ofac.treasury.gov/recent-actions/20260727
- Iran-Related Designations
https://ofac.treasury.gov/recent-actions/20260729
- Counter Terrorism Designations; Non-Proliferation Designation Update
https://ofac.treasury.gov/recent-actions/20260730
- Treasury Cracks Down on Global Networks Enabling Iran’s Mahan Air and IRGC
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE JULY 2026 Read More »
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE JUNE 2026
This newsletter is a listing of the latest changes in export control regulations through June 30, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
Strengthening Customs Enforcement
June 3, 2026: 91 Fed. Reg. 35125: The President issued Executive Order (“EO”) 14411 Strengthening Customs Enforcement. Customs enforcement is essential to the national security, foreign policy, and economy of the United States. Effective customs enforcement prevents the importation of unlawful and dangerous goods; ensures importers of record (IORs) are correctly identified and accountable for duties owed; and guarantees compliance with numerous Federal laws, including laws governing forced labor, rules of origin, origin marking, intellectual property, revenue collection, and product safety.
The President ordered the Secretary of Homeland Security to revise the regulations and polices to:
- Impose stricter Importer of Record requirements on foreign importers of record;
- Implement import disclosure and certification requirements;
- Increase enforcement and penalties;
- Streamline the seizure and disposal process; and
- Increase agency transparency.
Details of the EO can be found at the following links.
https://www.whitehouse.gov/presidential-actions/2026/06/strengthening-customs-enforcement/
https://www.federalregister.gov/documents/2026/06/10/2026-11595/strengthening-customs-enforcement
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Fact Sheet: The President Signed Directive on AI in the National Security Enterprise
June 5, 2026: The President signed a National Security Presidential Memorandum on Artificial Intelligence (AI) in the National Security Enterprise, establishing a new framework to put the most advanced, secure, and reliable AI systems into the hands of America’s warfighters and intelligence professionals while ensuring their responsible use.
- The Memorandum directs the national security enterprise to accelerate AI adoption to meet surging demand, adapt the best commercial and open-source technologies for mission use, assure that fielded systems are robust, steerable, controllable, and preserve clear lines of accountability under the Constitutional chain of command.
- The Memorandum strengthens national security capabilities, directing the rapid onboarding of the most advanced AI models from multiple vendors, driving the buildout of next-generation, high-security computing facilities to run future AI systems at scale, and bolstering the talent pipeline, including by establishing an AI National Security Strategic Reserve of top non-governmental experts.
- The Memorandum directs the Secretary of War to issue an updated directive on autonomy in weapon systems and requires annual review of key guidance across the national security enterprise to keep pace with the rapidly advancing AI frontier.
- The Memorandum directs departments and agencies to ensure that no entity, commercial or otherwise, can disable, degrade, or modify an AI system that American warfighters depend on without prior approval. It also offers new partnerships with willing private-sector companies to secure America’s cutting-edge AI against global threats.
- The Memorandum rescinds and replaces the Biden Administration’s NSM-25, an outdated document that burdened American AI adoption with ideological mandates and fostered dangerous single-vendor dependencies that left our warfighters exposed.
The complete fact sheet and the Presidential Memorandum can be found at the following links.
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Fact Sheet: The President Defends America’s Warfighters and Intelligence Officers Against Cyber Threats
June 12, 2026: The President signed a National Security Presidential Memorandum to bolster the cybersecurity of America’s National Security Systems (NSS) and modernize NSS governance to meet the cyber challenges of 2026 and beyond.
- NSS encompasses the US’ most sensitive computer systems – those that process classified information or support military and intelligence missions.
- The Memorandum establishes a clear structure, authorities, roles, and responsibilities for the governance of NSS and accountability to NSS cybersecurity requirements for its owners and operators.
- The Memorandum helps ensure that NSS owned or operated by civilian agencies receive a defense commensurate to those of the Department or War (DOW) and Intelligence Community (IC).
- The Memorandum reestablishes the Committee on National Security Systems (CNSS) and modernizes it for the first time in over 35 years to establish baseline cybersecurity requirements for all NSS and enhance accountability and coordination across agencies to implement necessary cyber defenses across all NSS.
- The CNSS will oversee the cybersecurity of NSS across the US Government and issue binding security directives to all NSS owners and operators.
- The CNSS will provide collaboration, standardization, and efficient resource management by promoting coordination and information sharing across Federal agencies, public-private partnerships, and international liaison activities.
- The CNSS will leverage the combined authorities and resources of the Federal Chief Information Officer, the Chief Information Officers of the DOW and IC, and the Director of the National Security Agency (NSA) to ensure that there are no gaps or weak links in NSS defenses.
- The Memorandum empowers the Director of the National Security Agency as the National Manager for National Security Systems and the cryptologic authority of NSS. It allows the Director to leverage the full technical power of the National Security Agency to provide advanced defenses and assistance in order to bolster the security of NSS across the U.S. government.
- The Memorandum promotes the efficient use of taxpayer dollars by encouraging the use of shared services in NSS and requiring the recission of outdated requirements.
- The Memorandum establishes a Policy Coordination Committee to work with the CNSS to request an assessment of NSS cybersecurity posture.
The complete fact sheet and the Presidential Memorandum can be found at the following links.
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The President Secures the Nation Against Advanced Cryptographic Attacks
June 22, 2026: The President signed an Executive Order (“EO”) 14412 to safeguard America’s most sensitive data, our critical infrastructure, and the digital economy that drives jobs and growth.
- The Order directs the Office of Management and Budget (OMB) and the National Cyber Director to lead an accelerated, nationwide migration to post-quantum cryptography (PQC), ensuring our Nation and our data stay secure as quantum technology evolves.
- The Order directs the Department of Commerce, the National Security Agency, and the Department of Homeland Security to deliver clear, practical guidance to agencies on effectuating and accelerating PQC migration. It also directs agencies to designate a PQC migration lead and to transition high value assets for certain uses to PQC by 2030 and 2031 depending on the use case.
- The Order directs the Department of Commerce to initiate a pilot project for PQC migration, to be completed by December 31, 2027.
- The Order directs the State Department and other Federal agencies to assist and encourage critical infrastructure operators, foreign governments, and foreign industry groups in their transitions to PQC, reinforcing U.S. leadership on the world stage.
- The Order directs OMB, the Department of War, the National Aeronautics and Space Administration, and the General Services Administration to coordinate efforts to identify cost-saving opportunities in the national PQC migration strategy.
- The Order directs the Federal Acquisition Regulatory Council to require covered contractors to meet certain Federal cybersecurity standards and vulnerability disclosure policies by the end of 2030.
Putting America First In Cybersecurity: The President promoted a key technology that will protect American systems in the quantum era, ensuring defense and resilience against potential disruptions to critical systems or data breaches.
- This Order is a bold, decisive step to protect the American people, preserve our economic strength, secure our global scientific leadership, and maintain our technological advantage for generations to come.
- By accelerating the U.S. Government’s PQC migration timeline, this Order ensures that American cybersecurity keeps pace with emerging technology and recognizes the reality of the accelerating quantum industry.
- The pilot program will showcase a successful migration by 2027, setting a clear example for agencies to fortify their cyber defenses as quantum technology advances.
- The Administration will help critical‑infrastructure owners adopt the same protections, keeping our power grids, water systems, and transportation networks safe.
The complete fact sheet and the EO can be found at the following links.
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Fact Sheet: The President Ushers in the Next Frontier of Quantum Innovation
June 22, 2026: The President signed Executive Order (“EO”) 14413 to supercharge U.S. innovation in quantum technologies and strengthen our national security in this critical area.
- The Order directs the Assistant to the President for Science and Technology, in coordination with other relevant government leaders, to update the National Quantum Strategy to support quantum-enabling technology and encourage partnerships with U.S. industry.
- The Order establishes a national effort to develop the first ever quantum computer powerful enough to initiate the era of quantum-enabled scientific discovery and accelerate quantum capabilities for commercial applications. This includes evaluations of quantum computing system capabilities, an assessment of the resources necessary to build this science-enabling quantum computer, and development of specifications for such a system.
- The Order directs the Assistant to the President for Science and Technology to coordinate this effort across the Departments of Energy, War, Commerce, and the Intelligence Community, as well as with U.S. industry and research leaders.
- The Order calls on the Secretaries of Commerce, War, and Energy and the NASA Administrator to develop plans to deploy quantum-enabled sensors and networks in the next five years.
- The Order prioritizes the development of a strong American quantum workforce through the expansion of registered apprenticeships, credentials, and the creation of National Quantum Workforce Development Institutes. It also directs the development of a plan and other measures to ensure adequate domestic supply chains and manufacturing capabilities for quantum technologies, as well as appropriate funding support for such efforts.
- The Order reconstitutes the National Quantum Initiative Advisory Committee and directs the expansion of the Quantum Counterintelligence Protection Team. It also directs appropriate engagement with international partners on quantum matters.
Strengthening America’s Quantum Advantage: The President recognizes that quantum technologies are on the verge of a massive commercial breakthrough and require a bold new policy approach to ensure America continues to lead the field.
- Quantum technologies, like a quantum computer or a quantum sensor, will provide transformational capabilities in manufacturing, drug discovery, energy, agriculture, and more. These breakthroughs will drive American innovation, power economic growth, generate high-paying jobs in existing and entirely new industries, and bolster national security.
- Competing nations are moving quickly to challenge America’s quantum leadership, including adversarial countries that would use quantum to undermine U.S. economic and national security.
- The Order ensures that the United States enters this new era of quantum innovation with ambitious national goals, a strong domestic workforce, and trusted supply chains in coordination with our international allies and partners.
The complete fact sheet and the EO can be found at the following links.
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Department of State, Directorate of Defense Trade Controls (DDTC)
Proposed Rule: ITAR Part 130 Changes to Reduce Reporting Burden
June 15, 2026: 91 Fed. Reg. 35926: DDTC published in the Federal Register a proposed rule to revise Part 130 and related sections of the International Traffic in Arms Regulations (ITAR) to modernize, streamline, and standardize reporting on certain political contributions and fees or commissions related to the sale of defense articles and defense services to or for a foreign military or international organization.
The proposed revisions include:
- Increasing the monetary thresholds that trigger reporting of political contributions and fees or commissions to account for inflation;
- Consolidating reporting to the Department to a single annual submission, rather than on a transaction-by-transaction basis; and
- Implementing an electronic submission form to reduce administrative burden and to collect and report more accurate information.
The proposed rule is in support of the policy directed in Executive Order 14268 to reduce rules and regulations involved in the development, execution, and monitoring of foreign defense sales and arms transfer cases.
Comments are accepted until August 14, 2026.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=7e2e0eb71b91c354fd4d87f4604bcbf7
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Fraudulent DTCC Communications
June 25, 2026: The Directorate of Defense Trade Controls posted to its homepage that it has become aware of certain companies receiving fraudulent communications purporting to be directed disclosures from the Office of Defense Trade Controls Compliance (DTCC). The fraudulent communications in question are not from DTCC, and these fraudulent communications have been referred to the relevant law enforcement authorities. If you believe that you may have received such fraudulent communications, do not respond or click on any hyperlinks or attachments without first reaching out to DTCC at DTCC-CaseStatus@state.gov to confirm the authenticity of the correspondence.
https://www.pmddtc.state.gov/ddtc_public
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Guidelines for Preparing Agreements Revision 5.2 Released
June 26, 2026: The Directorate of Defense Trade Controls posted to its website Guidelines for Preparing Agreements Revision 5.2. The guidelines went into effect on May 26, 2026. Revision 5.2 makes the following changes:
- All ITAR § 124.8(a)(5) references in the document have been revised to include reference to new ITAR § 126.7 to clarify that the exemption may be used to retransfer and reexport defense articles pursuant to this exemption that were originally exported via an agreement*
- Modifies Sections 8 (Congressional Notification) and 15 (Exporting Hardware in Furtherance of Agreements) to remove guidance that has been moved to stand-alone web documentation
- Congressional Notification Guidance. General guidance on the Congressional Notification process formerly found in Version 5.1, Section 8, is now available here:
Home → Conduct Business → Congressional Notifications
- “In Furtherance Of” licenses. Guidance on the submission of IFO licenses is now available here:
Home → Conduct Business → Licenses, Agreements, and Other Authorizations → License Guidance → License Applications in Furtherance of (IFO) an Agreement
- Modifies Section 10.3 (Requests for DDTC Vetting of § 126.1 Nationals) to conform with current DDTC practice of requiring names for all § 126.1 dual and third country nationals (DN/TCN) when DDTC vetting is requested
- Clarifies that the requirement to identify end-use platforms includes end-use systems and variants Clarifies that end-use platforms and end-use systems, including variants, must be included in the description in block 20 of the DSP-5 vehicle
- Reconciles the “Contract Employee” clause in Section 11.3 (Agreement Language for Non-Regular Contract Employees) with the clause in Section 2.2 ((TAA/MLA Template).
- Reconciles the “Expedited Execution” clause in Section 2.2 (TAA/MLA Template) with the clause in Section 13.1 (Expedited Execution)
- Corrects minor typographical errors found in Revision 5.1 (Uploading Submission Documents)
*Agreements must conform to the ITAR §124.8(a)(5) statement’s current language at the next amendment, whether major or minor. Note that parties to an agreement MAY NOT use the ITAR §126.7 exemption to reexport or retransfer defense articles originally exported via an agreement unless the agreement has been updated. Refer to the applicable FAQ.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=f8033cd597b98f5067b1791ad053af3d
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DDTC Name And Address Changes Posted To Website
June 1 through June 30, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Applied Intuition, Inc. changed its address from 145 E. Dana St, Mountain View, California 9404 to 860 W. California, Sunnyvale, CA 94086;
- ARKA Group, L.P. changed its address from 100 Wooster Heights Road, Danbury, CT 06810 to 12021 Sunset Hills Road, Reston, VA 21090;
- Siemens Industry Software ULC/Siemens Logiciels (Industrie), ULC changed its name to Siemens Industry Software Limited/Siemens Logiciels (Industrie), Limitee as a result of a rebranding; and
- Arcam AB, Designvagen 2, Molnlycke 435 33 Sweden changed its address to Flojelbergsgatan 10, Molndal, 433 37, Sweden.
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
- Vietnam – C-130 Sustainment
- New Zealand – MH-60R Multi-Mission Helicopters
- New Zealand – MK 54 Torpedoes
- Republic of Korea – Joint Direct Attack Munitions
- Italy – Assault Amphibious Vehicles
- Kuwait – Counter-Unmanned Aerial Systems Platforms
- Denmark – Joint Air-to-Surface Standoff Missiles with Extended Range
- United Kingdom – Large Aircraft Infrared Countermeasures
- Republic of Korea – AIM-120C-8 Advanced Medium Range Air-to-Air Missiles
- Brazil – FIM-92K Stinger Missiles
- Singapore – Common Fire Control System
- Austria – UH-60M Black Hawk Helicopters
- Australia – F/A-18F & EA-18G Growler Aircraft Training
- Advancing Trilateral Cooperation to Disrupt Democratic People’s Republic of Korea (DPRK) Cyber-Enabled Revenue Generation
- Singapore – Hellfire Missiles
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Department of Defense – Office of the Under Secretary of Defense (Acquisition and Sustainment)
June 10, 2026: 91 Fed 35189: The Deputy Secretary of Defense published its list of entities that qualify for designation as “Chinese military companies,” are engaged in providing commercial services, manufacturing, producing, or exporting (as required by Section 1260H(g)(2)(B)(ii)), and operate directly or indirectly in the United States (as required by Section 1260H(a)) in accordance with section 1260H.
This list prohibits the Department of Defense (“DOD”) or Department of War (“DOW”) from procuring goods from listed entities. For exporters and importers this list should be incorporated into the sanctioned, denied and restricted party screening process to identify risk or red flags that could impact its business.
A company contemplating engaging in a transaction with a DOD listed entity, that is not listed on a sanctioned, denied or restricted party list should consider the following:
- Increased risk of the DOD listed entity being placed on a sanctioned, denied or restricted party list.
- Licensing requirement under § 744.20 which requires a BIS export license for ECCN listed in Supplement No. 2 to Party 744 when there is knowledge that the item will be used by among others, the Chinese military or an entity the supports the Chinese military or military end use.
- Licensing requirements under § 744.21 for all items subject to the EAR when there is knowledge that the item will be used by among others, the Chinese military intelligence, an entity the supports the Chinese military intelligence, or Chinese military intelligence.
- The implications of the BIS 50% rule (coming this fall), Part 744.20 – Restrictions on certain military end uses or military end users, and Part 744.21 – Restrictions on exports, reexports, and transfers to certain military-intelligence end uses or end users when engaging with a DOW listed entity in the US.
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Department of Energy – National Nuclear Security Administration (NNSA)
Assistance to Foreign Atomic Energy Activities
June 16, 2026: 91 Fed. Reg. 36071: On June 16, 2026, the Department of Energy issued a final rule to add Thailand to the generally authorized destinations for exports of controlled nuclear technology and assistance under DOE’s regulation on Assistance to Foreign Atomic Energy Activities.
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General Services Administration
General Services Acquisition Regulation; Acquisition of Information and Communication Technology; Notice of Listening Sessions and Request for Comments
June 17, 2026: 91 Fed. Reg. 36559: The General Services Administration (GSA) is seeking public comment on the draft of a new General Services Administration Acquisition Regulation (GSAR) clause regarding basic safeguarding of data within Large Language Model Artificial Intelligence Systems (LLMs). Due to the complexity of the issue, GSA is publishing this notification and draft clause to gather feedback from stakeholders before taking future action ( e.g., deviation and/or formal rulemaking).
The rapid advancement and adoption of Large Language Model Artificial Intelligence (LLM) systems present both unprecedented opportunities and significant challenges for Federal agencies. As GSA establishes contracts for these technologies, ensuring the integrity, security, and appropriate handling of Government Data is paramount. This notification introduces a new GSAR clause, 552.239-7001, “Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems (LLMs),” to address these critical concerns. This clause may be used in GSA’s Government-wide contracts ( e.g., Federal Supply Schedule, GWACs, and OASIS+).
This clause is developed in response to the growing use of LLMs across Government and the need for a standardized approach to data protection, intellectual property, and ethical AI development when LLM’s are used to process Government data. It is informed by principles outlined in Executive Orders ( e.g., Executive Order 14110, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence and OMB Memorandums (e.g., OMB memorandum M-25-22, Driving Efficient Acquisition of Artificial Intelligence in Government, and comments received on the first draft of this clause. The first draft was issued through GSA Interact on January 12, 2026 ( https://buy.gsa.gov/interact/community/6/activity-feed/post/4d70761f-60f8-4eb0-8119-052ec4c7c9b3/Advanced_Notice_for_MAS_Refresh_31_and_Upcoming_Mass_Modification).
Interested parties should submit written comments as noted below on or before August 3, 2026, to be considered in the formation of the final GSAR clause.
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Department of Homeland Security – U.S. Customs and Border Protection
Indefinite Suspension of the De Minimis Exemption for Mail Shipments and New Postal Informal Entry Process
June 24, 2026: 91 Fed. Reg. 37801: U.S. Customs and Border Protection (CBP) published an interim final rule implementing an indefinite suspension of the de minimis administrative exemption for imports valued at $800 or less arriving through the international postal network. This interim rule also establishes a new postal informal entry process for certain merchandise entering the United States through the mail environment.
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Indefinite Suspension of the De Minimis Exemption for Merchandise Arriving Through All Modes Other Than the International Postal Network
June 24, 2026: 91 Fed. Reg. 37789: U.S. Customs and Border Protection (CBP) published an interim final rule implementing an indefinite suspension of the de minimis administrative exemption for imports valued at $800 or less arriving via all modes other than through the international postal network. This indefinite suspension means that all entries of merchandise valued at $800 or less arriving through all modes other than the international postal network must utilize formal or informal entry procedures.
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
Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control, and FTI Consulting, Inc.
June 1, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with FTI Consulting, Inc. (“FTI”). FTI agreed to remit $1,050,000 to settle its potential civil liability for its apparent violations of OFAC sanctions targeting Russia’s financial sector. Between April 2019 and May 2021, FTI indirectly dealt in prohibited debt of VTB Bank OAO (“VTB”), a Russian state-owned bank, on six occasions. These prohibited dealings occurred when FTI extended debt of more than 14 days maturity to VTB by indirectly issuing invoices to VTB that went unpaid or were paid long past the expiration of the permissible 14-day tenor. All the while, even when invoices remained unpaid for long periods, FTI continued to perform valuable services for the benefit of VTB and continued to extend prohibited debt to VTB.
FTI is often engaged by law firms to provide consulting services in support of firms’ clients. In late 2018, a global law firm reached out to an FTI Senior Managing Director in the economic consulting unit about engaging FTI to provide expert economic consulting services on behalf of the law firm’s client, VTB, for a civil suit in Singapore. FTI, the law firm, and VTB soon thereafter agreed in principle to have FTI support VTB in the litigation, with the actual contract forthcoming. At that time, and at all relevant times thereafter, U.S. persons were prohibited from certain dealings with VTB because VTB had been added to OFAC’s Sectoral Sanctions Identification (SSI) list. Specifically, VTB was subject to Directive 1 under Executive Order (E.O.) 13662 (“Directive 1”), which prohibits U.S. persons from dealing in new debt of more than 14 days maturity of any person subject to it; the Directive also prohibits any transaction that evades or avoids any of the prohibitions set forth in Directive 1. OFAC’s guidance on Directive 1 explains that the issuance of an invoice by a U.S. person is an example of new debt subject to the restrictions of Directive 1, that U.S. persons are prohibited from extending debt with an impermissible term to a non-sanctioned party if an SSI entity is an indirect borrower, and that such debt may not be issued “for the benefit of” an SSI entity by a U.S. person.2party if an SSI entity is an indirect borrower, and that such debt may not be issued “for the benefit of” an SSI entity by a U.S. person.
In early 2019, FTI’s chief compliance officials, who recognized that dealing with VTB could expose FTI to sanctions risks, deliberated over different payment options for the provision of FTI’s economic consulting services for VTB. Pursuant to the compliance officials’ advice, and in collaboration with the law firm and VTB, FTI set up its engagement in support of VTB to be directly with the law firm. As agreed in the attendant letter of engagement between FTI and the law firm, FTI would issue invoices to the law firm; upon the law firm’s receipt of payment from VTB for FTI’s invoices, the law firm would pay FTI. FTI had no recourse to collect payment from the law firm unless and until the firm received payment from VTB for payment of FTI’s invoices. FTI also had no recourse against VTB if the invoices went unpaid.
In April 2019, FTI performed work on the litigation matter and sent the law firm two invoices. The law firm then sent the invoices, totaling approximately $54,000, to VTB for payment. By indirectly issuing invoices that VTB was ultimately responsible for paying, FTI extended new debt to VTB.
In May 2019, FTI had yet to be paid for the two invoices it had already issued when it began discussions with the law firm about performing additional work for the same litigation matter in Singapore. The law firm relayed messages between FTI and VTB about the scope of the work and budget, which was subject to VTB’s approval. As with the prior engagement, an FTI Senior Managing Director based in New York consulted with FTI’s Legal and Compliance departments regarding the engagement’s terms and during the second engagement. FTI and the law firm agreed to use the same payment structure as the first engagement (which VTB had approved), where the law firm was engaged as FTI’s client in the letter of engagement, with payment of FTI’s fees subject to the law firm first receiving payment from VTB. FTI and the law firm agreed to use a retainer for the second engagement, which called for FTI drawing down funds against a retainer VTB would first pay to the law firm.
On June 7, 2019, FTI sent the law firm an invoice of approximately $90,000 for the retainer payment, which the law firm told FTI it had sent to VTB, and assured FTI that the law firm would get payment from VTB for FTI. VTB, however, did not make the retainer payment. Despite the lack of funding for the retainer, FTI commenced work on the second engagement and sought payment that would have originated from VTB for the retainer. In late June 2019, FTI joined a call with the law firm and VTB to discuss the overdue payments.
Despite not receiving payment for the two April 2019 invoices for the first engagement, nor payment for its third invoice for the retainer for the second engagement, FTI continued to work on the VTB litigation matter by drafting expert economic analysis. On July 4, 2019, FTI inquired again about VTB’s lack of payment for the retainer amount and requested the law firm set up another call with VTB if it continued to fail to make the outstanding payment. FTI issued its fourth invoice on July 13, 2019; by that time the first three invoices were outstanding for 99, 92, and 35 days, respectively. FTI continued to work on the VTB matter without receiving payment and issued its fifth invoice on July 24, 2019. In September 2019, VTB made a partial payment of approximately $57,000 to the law firm for the retainer invoice, 90 days after FTI had first issued the invoice; the law firm in turn paid FTI. FTI issued its sixth and final invoice for the VTB matter on November 26, 2019.
As of March 2020, after having issued six invoices with a total value of approximately $353,862, FTI had received only one partial payment for one of the six invoices. At that time, FTI’s Senior Manager leading the consulting engagement sought assistance from FTI’s compliance officer to resolve VTB’s lack of payment. FTI subsequently told the law firm it expected the law firm to pay all outstanding invoices using its own funds. The law firm, however, reiterated the terms of the letter of engagement and told FTI that the law firm did not take on the credit risk of VTB not making payment. In June 2020, VTB made a second payment of approximately $19,400 for one of FTI’s invoices to the law firm, followed by the law firm paying FTI, 198 days after FTI had issued the invoice. FTI continued to seek answers and payments from the law firm until May 2021, when the law firm notified FTI that it was no longer representing VTB. FTI did not attempt to collect payment from the law firm after the law firm terminated its relationship with VTB. FTI subsequently submitted a notification of a potential violation to OFAC after investigating FTI’s actions.
Under § 589.202(c) of the Ukraine-/Russia-Related Sanctions Regulations (URSR), 31 C.F.R. part 589, the following activities by a U.S. person or within the United States are prohibited: for new debt or new equity issued on or after November 28, 2017, all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity of persons determined to be subject to Directive 1, their property, or their interests in property. Moreover, the prohibition in Directive 1 of E.O. 13662, as implemented in § 589.213 of the URSR, 31 C.F.R. part 589, prohibits any transaction on or after the effective date that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions set forth in 31 C.F.R. part 589.
Between April 2019 and May 2021, FTI appears to have violated §§ 589.202 and 589.213 on six occasions when FTI dealt in new debt of longer than 14 days maturity to VTB, an entity that at the time of the transactions was subject to the prohibitions of § 589.202 of the URSR. FTI dealt in new debt of VTB through its indirect issuance of invoices, which represented new debt subject to the restrictions of Directive 1, to VTB, which VTB was responsible for paying and from which VTB benefited (the “Apparent Violations”).
The settlement amount of $1,050,000, aggravated above the base penalty, reflects OFAC’s consideration of the General Factors under the Enforcement Guidelines, in particular the importance of anticipated impact of promoting future compliance by similarly situated persons.
OFAC determined the following to be aggravating factors:
- FTI, with the involvement of certain senior managers, recklessly missed multiple warning signs that it was dealing in prohibited debt of VTB. At the outset of the engagement, FTI was aware of and discussed the prohibitions applicable to VTB; the risks it identified informed the unique payment arrangement FTI entered into with the law firm. Thereafter, despite believing the arrangement lawfully shielded FTI from the risk of violation, FTI should have realized it was dealing in prohibited debt of VTB when it repeatedly issued invoices for ultimate payment by VTB, continued to work on and issue new invoices for the VTB matter despite not being paid by VTB, and joined a call with VTB to discuss late payments. Another warning sign arose when the law firm told FTI that the law firm did not take on the credit risk of VTB’s non-payment of FTI’s invoices.
- FTI harmed the objectives of the sanctions program by extending an impermissibly long period of credit to VTB when the aim of U.S. sanctions policy was to prevent VTB from receiving such benefits. The indirect payment arrangement caused harm by obscuring transaction activity that, under a direct payment arrangement, could have successfully been screened against by intermediary parties.
- FTI is a large and commercially sophisticated entity with an extensive global presence, providing consulting services to international business entities in various industries and jurisdictions. In light of OFAC’s broad prohibitions on indirect dealings with sanctioned persons, this action seeks to promote greater awareness and scrutiny of such undertakings and deter future violations by the subject person and other similarly situated persons.
OFAC determined the following to be mitigating factors:
- FTI agreed to toll the statute of limitations and cooperated with OFAC’s investigation by providing comprehensive contemporaneous documentation about the underlying conduct, including by waiving privilege.
- The volume and amount of the transactions at issue is very small compared to the total amount of payments that FTI makes and receives from clients and law firms.
- FTI has made enhancements its sanctions compliance program, including by: (1) requiring training that addresses sectoral sanctions and raising awareness within its legal department with respect to law firm engagements in particular; (2) updating its sanctions compliance and restricted party screening policies and procedures; (3) supplementing its sanctions compliance resources; and (4) bolstering risk assessments and implementing additional controls in response to Russia’s full-scale invasion of Ukraine.
- FTI has not been the subject of a Finding of Violation or Penalty Notice by OFAC in the past five years.
https://ofac.treasury.gov/recent-actions/20260601_33
https://ofac.treasury.gov/media/935651/download?inline
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CEO of Iran Tech Company Arrested on Federal Charge of Supplying U.S. Equipment to Iran’s Nuclear and Military Establishment
June 3, 2026: The U.S. Department of Justice announced the arrest of a dual U.S.-Iranian national and CEO of an Iran-based technology company for violating U.S. sanctions against Iran by acquiring sophisticated U.S.-origin networking, security, and encryption equipment for Iranian customers — including the Iranian regime’s nuclear and military establishments.
According to the affidavit filed with the complaint, Ghomi is the founder, owner, and CEO of Faraz Pardaz Rayaneh Co. Ltd. (FPR), a Tehran-based computer networking company. For more than a decade, Ghomi has used FPR to procure U.S.-origin networking equipment for customers in Iran in violation of U.S. sanctions. Ghomi or FPR never obtained a license from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) authorizing those transactions.
Ghomi identified, negotiated, purchased, and arranged the shipment of large quantities of controlled U.S. technology for his own company. From 2011 to 2015, he used his own eBay and PayPal accounts to make more than 400 purchases of computer-networking equipment, directing the goods to intermediaries in the United Arab Emirates (UAE). In 2023, Ghomi personally negotiated the purchase of U.S.-origin networking equipment directly from suppliers in Minnesota and Nebraska, routing it through a UAE front company and on to FPR in Iran.
None of these items could be lawfully exported to Iran without a license from OFAC.
From 2014 to 2018, Ghomi arranged the smuggling of more than 250 metric tons (275.6 U.S. tons) of networking equipment into Iran, using freight forwarders and intermediaries in Dubai to disguise that Iran was the true destination.
“Ghomi is accused of aiding our declared enemies by selling U.S.-origin computer networking parts to Iran and earning millions of dollars in violation of U.S. sanction laws,” said First Assistant U.S. Attorney Bill Essayli for the Central District of California. “Our nation’s laws prohibiting doing business with one of the world’s largest state sponsors of terrorism must be enforced and obeyed. We will hold him accountable by seeking an appropriate prison sentence and by seizing his assets, including his $35 million Newport Beach mansion.”
Ghomi knew this conduct was illegal and took deliberate steps to conceal it. He directed his UAE co-conspirators to keep his name off shipping paperwork, to omit invoices from shipments bound for Iran, and on at least two occasions to hide U.S.-origin computer equipment inside larger shipments. He used front companies in the UAE to obscure his role, and he personally received warnings on invoices and software licenses that exporting these goods to Iran was prohibited. Ghomi and his co-conspirators referred to Iran as “Motherland” in their internal correspondence concerning the equipment’s procurement.
FPR’s annual sales exceeded $10 million and ran to hundreds of Iranian companies and government entities, many of which were subject to U.S. sanctions. A relatively small but significant portion of that business went to the most sensitive end-users in Iran: the Iranian regime’s nuclear and military establishment.
From 2017 to 2023, FPR supplied U.S.-origin computer networking equipment to the Atomic Energy Organization of Iran (AEOI) — the Iranian government agency responsible for Iran’s nuclear program, including its centrifuge and uranium-enrichment programs. The U.S. State Department sanctioned AEOI in 2020 for playing a leading role in Iran’s nonperformance of its nuclear commitments, including exceeding the limits on its uranium stockpile and enrichment levels.
According to the affidavit, AEOI required FPR to register as an approved vendor, which it did in 2021 and 2022. From 2014 to 2022, FPR supplied U.S.-origin networking, security, and encryption equipment to Iran’s Ministry of Defense and Armed Forces Logistics — the Iranian ministry responsible for research, development, and manufacturing across Iran’s defense enterprise — and to affiliated military and defense-electronics entities. FPR’s 2017 contract with Iran Computer Industries, signed by Ghomi, expressly identified the buyer as the “Ministry of Defense and Armed Forces Logistics — Iran Computer Industries.”
Ghomi laundered the proceeds of his illegal business into the United States, depositing FPR’s Iranian sales revenue into its operating account at a sanctioned Iranian bank and then sweeping those funds to himself. Within days, he received corresponding wires into his U.S. accounts from a rotating set of unrelated trading companies and exchange houses in the British Virgin Islands, Hong Kong, Turkey, and the UAE. Those wires bore false descriptions such as “Buying Goods” and “For Consulting Fees.”
From 2011 to 2024, Ghomi moved more than $15 million from Iran into his U.S. bank accounts and into a construction escrow account held on his behalf. He falsely reported those funds to the IRS as a foreign inheritance. Ghomi’s federal tax returns reported almost no income, his highest reported income in any year being $20,684. Ghomi claimed the Earned Income Tax Credit, a federal tax break for low- to moderate-income working individuals and families, in seven different tax years. Over the same period, Ghomi reported more than $1.7 million in home-mortgage interest and $1.25 million in state and local real-estate taxes on his federal income tax returns.
If convicted, Ghomi would face a maximum penalty of 20 years in prison.
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Robert Bosch GmbH (Bosch) To Pay $36 Million Penalty to BIS for Violations Pertaining to Shipments to Huawei
June 17, 2026: The Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement agreement with Robert Bosch GmbH (Bosch), headquartered in Stuttgart, Germany, covering shipments of foreign-produced items to Huawei Technologies Co. (Huawei), or its affiliates.
Between September 16, 2020 and September 26, 2024, Bosch through its German subsidiaries, committed 109 violations of the EAR when they sold, transferred, and/or exported abroad approximately $72,369,361 worth of Micro-Electro-Mechanical Systems (“MEMS”) sensor products and automotive software, items subject to the Export Administration Regulations (the EAR) pursuant to the Foreign Direct Product Rule (“FDP Rule”), to Huawei and its affiliates on the Entity List without the required license or other authorization from BIS. The MEMS sensors at issue have a broad range of consumer applications, including in smartphones, wearable technology, and automobiles.
Key points from the Charging Letter:
- Bosch produced MEMS in Germany using non-U.S. equipment that were the direct product of U.S. origin “technology” or “software” specified in an ECCN identified in the FDP Rule. Additionally, Bosch used microcontrollers produced by a non-U.S. company in the testing of the hardware-dependent Bosch produced software for automotive Electronic Control Units (“ECUs”). The microcontrollers were the direct product of U.S.-origin “software” or “technology” specified in an ECCN identified the FDP Rule and were a major component of a plant that produced the Bosch software.
- Bosch had “knowledge” that Huawei was an “end-user” and, therefore, a party to the transactions involving the MEMS and the ECU software, Bosch was prohibited from exporting from abroad to Huawei the MEMS and ECU software produced using equipment and microcontrollers subject to the FDP rule without a BIS license.
- In general, Bosch had established compliance processes and procedures regarding export compliance, including U.S. export compliance. However, Bosch’s U.S. export compliance team did not have sufficient expertise or resources at the time to adequately address the August 2020 changes to the EAR, namely, the FDP Rule that expanded the restrictions for Huawei.
- In one instance, the trade compliance employee in Germany erroneously commingled the concept of the De Minimis Rule, which depends on a certain amount of incorporated U.S. origin content that is controlled for a destination, and the concept of the FDP Rule, which depends on the software, technology, and equipment used to produce an item rather than incorporated content.
- Bosch overlooked indications from equipment suppliers warning Bosch of the impact of the FDP Rule and products produced using equipment subject to the EAR’s FDP Rule.
Bosch filed a Voluntary Self-Disclosure and cooperated with the investigation.
Bosch agreed to pay a penalty of $36,184,680. Bosch also agreed with the Department of Justice to disgorge profits, partially suspended, with actual payment of approximately $3.6 million. BIS is suspending approximately $3.6 million of its penalty as credit for the disgorgement.
Assistant Secretary of Commerce for Export Enforcement David Peters stated: “Bosch had several opportunities to avoid these violations had they exercised the increased vigilance BIS has repeatedly said it expects of companies whose transactions are governed by the EAR. Today’s action should serve as a warning to embrace compliance and as an example of the benefits of voluntary self-disclosure.”
https://www.bis.gov/media/documents/robert-bosch-gmbh-final-order-6-16-2026.pdf
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National Security Division Announces First Declination Under the Department-wide Corporate Enforcement Policy
June 17, 2026: The Justice Department announced that it has declined the prosecution of Robert Bosch GmbH (Bosch), thereby resolving its investigation into an alleged scheme to send products and software manufactured with equipment that was the direct product of U.S. software or technology to an Entity-listed company in the People’s Republic of China (PRC). This decision was reached pursuant to Part I of the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), after also considering the factors set forth in the Department’s Principles of Federal Prosecution of Business Organizations. Bosch promptly disclosed the misconduct to the National Security Division (NSD), fully cooperated, and timely and appropriately remediated — which qualified them for a declination under the CEP, given that aggravating circumstances were absent Bosch has agreed to disgorge the $11,430,098 in profits it made as a result of the transactions at issue — a portion of which will be credited towards the $36,184,680 fine paid in a parallel civil action by the Department of Commerce.
As announced by NSD on March 30, enforcing export control and sanctions laws is a top priority and furthers NSD’s mission to protect and defend the United States against the full range of national security threats. Moreover, the Justice Manual (JM) assigns violations of the U.S. government’s primary export control and sanctions regimes, among other criminal laws affecting, involving or relating to the national security, to NSD. JM 9-90.020. This is the first time that NSD has declined the prosecution of a company under the CEP.
“This declination reflects the clear benefits for companies that promptly disclose potential violations and fully assist in our investigations,” said Assistant Attorney General for National Security John A. Eisenberg. “Bosch’s cooperation and timely remediation met the high standards set by the Corporate Enforcement Policy, supporting a fair and efficient resolution. This first-of-its-kind decision by NSD highlights the important role of transparency in safeguarding U.S. technology and national security.”
“This settlement agreement underscores BIS’s commitment to strong enforcement as well as incentivizing voluntary disclosures of past violations,” said Assistant Secretary of Commerce for Export Enforcement David Peters.
Between September 2020 to September 2024, Bosch, through two of its non-U.S. based subsidiaries, exported over $70 million worth of foreign-produced Micro-Electro-Mechanical Systems sensor products and foreign-produced software to Huawei Technologies Co., Ltd. and its affiliates on the Entity List, including Huawei Tech. Investment Co. Ltd. Hong Kong (collectively, Huawei) without the required license or authorization from the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) in violation of the Export Administration Regulations (EAR), 15 C.F.R. Parts 730-744. The two implicated subsidiaries are Bosch Sensortec GmbH (BST) and ETAS GmbH (ETAS). In particular, BST and ETAS provided to Huawei foreign-produced items that were subject to the EAR pursuant to the Entity List Foreign Direct Product Rule (FDPR) for entities designated with “Footnote 1.” The investigation further revealed that Bosch’s trade compliance personnel were ill-equipped to provide accurate guidance on the FDPR, which led to several years of FDPR violations. In addition, the investigation identified ongoing sales in violation of the FDPR despite several missed opportunities where third-party companies identified potential applications of the FDPR to their products or equipment used in the provision of their services. As a result, Bosch made approximately $11,430,098 in pre-tax profits.
Bosch voluntarily self-disclosed the misconduct to NSD. Bosch cooperated with NSD’s investigation, including by preserving and proactively disclosing relevant facts, information, and documents about the conduct and promptly responding to NSD’s subsequent requests. Bosch also timely and appropriately remediated the misconduct by making organizational changes, imposing disciplinary action, adding employees to its trade compliance organization, expanding its U.S. trade compliance resources, and updating its internal policies and procedures. Given all of the above and the lack of aggravating circumstances, the Department is declining to prosecute Bosch, and Bosch has agreed to a disgorgement of the $11,430,098 in profits.
Trial Attorney Maria Fedor of the National Security Division’s Counterintelligence and Export Control Section prosecuted the case with investigative assistance provided by the Department of Commerce, Bureau of Industry and Security.
https://www.justice.gov/d9/2026-06/bosch_-_executed_declination.pdf
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MAAG Gala, Inc. Agree to Pay $67,000 For Eighteen Violations of the Antiboycott Regulations.
June 18, 2026: The Office of Antiboycott Compliance (“OAC”), Bureau of Industry and Security (“BIS”) announced a settlement with MAAG Gala, Inc. (“MAAG”) in which MAAG agreed to pay $67,000 for eighteen violations of the antiboycott regulations described in Part 760 of the Export Administration Regulations (“EAR”).
MAAG voluntarily disclosed to the OAC that it had committed eighteen violations of the § 760.5 of the EAR when it failed to report the receipt of a request to engage in a restrictive trade practice or boycott.
Between 2021 – 2024, MAAG received the requests in the terms and conditions for 18 Purchase Orders (“PO”) for spare parts from one customer located in Qatar. Each PO included the language “Israeli origin goods are not permitted to import into Qatar” or “Follow Qatar import regulations on restricted, banned, and boycotted origin goods.”
https://www.bis.gov/media/documents/a780-maag-gala-inc.pdf
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Eastern District of New York | Manager of U.S. Freight Forwarding Company Sentenced to 18 Months in Prison for Circumventing Export Controls | United States Department of Justice
June 24, 2026: The U.S. Attorney’s Office of Eastern New York, announced Natalya Ivanovna Mazulina, also known as “Natasha Mazulina,” a resident of Federal Way, Washington, was sentenced to 18 months in prison for crafting a scheme to circumvent U.S. export laws related to Russia. Mazulina was the Western Regional Manager of Delex Air Cargo LLC, a freight forwarding company based in Jamaica, New York, which operated out of John F. Kennedy International Airport and Seattle-Tacoma International Airport. Mazulina was arrested in December 2024 and, in October 2025, pled guilty to conspiracy to violate the Export Control Reform Act. As part of her sentence, Mazulina was ordered to forfeit $77,000 in criminal proceeds.
“The Russian oil and gas industry is the lifeblood that fuels the Russian war machine,” stated United States Attorney Nocella. “This defendant put her own profits above the national security of the United States by conspiring to illegally export industrial oil and gas equipment to Russia. Our Office will continue to use all our law enforcement tools to investigate and prosecute those who evade export control laws.”
From at least December 2022 through December 2024, Mazulina conspired with Russian freight forwarding companies and others to unlawfully ship controlled items, including industrial oil and gas equipment, from the United States to Russia, through intermediary countries. At one point, in June 2023, Mazulina told colleagues that her clients were paying through bank accounts in third party countries because “[m]ost of [her] clients [were] currently sanctioned with USA.” Mazulina attempted to conceal the unlawful scheme by submitting and causing the submission of false export documents to the U.S. government, which omitted the information that the goods were destined for Russia.
“This case shows that BIS will work with our law enforcement partners to aggressively pursue all those who violate our export control laws,” stated Special Agent in Charge Guanci.
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for June 1 through June 30, 2026.
- Publication of Introduction to OFAC Guide
https://ofac.treasury.gov/recent-actions/20260601
https://ofac.treasury.gov/media/935656/download?inline
- Counter Terrorism and Iran-related Designations; Democratic Republic of the Congo-related Designations; Issuance of Iran-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260602
- Cuba Designations; Issuance of Cuba-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260604
- Iran-related Designations; Counter Terrorism Designations Updates
https://ofac.treasury.gov/recent-actions/20260605
- Non-Proliferation Designations; Iran-related Designations; Issuance of Venezuela-related Amended General Licenses and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260610
- Cuba Designation; Russia-related Designations Removals and Designation Update; Issuance of Amended Russia-related General Licenses and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260611
- Issuance of Venezuela-related General Licenses and Amended Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260618_33
- Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260618
- Issuance of Iran-related General License
https://ofac.treasury.gov/recent-actions/20260622_33 - Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260622 - Transnational Criminal Organizations Designations; Cuba Designations; Russia-related Designations Removals; Issuance of TCO-related General License; https://ofac.treasury.gov/recent-actions/20260623
https://home.treasury.gov/news/press-releases/sb0538
https://ofac.treasury.gov/media/936216/download?inline
- Publication of OFAC-OFSI Comparative Overview
https://home.treasury.gov/news/featured-stories/achieving-our-objectives-supporting-our-stakeholders-ofac-ofsi-enhanced-partnership-exchange-2026 https://ofac.treasury.gov/media/936221/download?inline
- Democratic Republic of the Congo-related Designations; Issuance of Amended Russia-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260625 - Issuance of Venezuela-related General License
https://ofac.treasury.gov/recent-actions/20260625_33
- Sudan-related Designations
https://ofac.treasury.gov/recent-actions/20260626
- Launch of OFAC Reconsideration Portal
https://ofac.treasury.gov/recent-actions/20260629_33
- Counter Narcotics Designations; Russia-related Designations Removals; Publication of Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act (TSRA)
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE JUNE 2026 Read More »
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE MAY 2026
This newsletter is a listing of the latest changes in export control regulations through May 31, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
Imposing Sanctions On Those Responsible For Repression In Cuba And For Threats To United States National Security And Foreign Policy
May 1, 2026: 91 Fed. Reg. 25061: The President issued Executive Order 14004 Imposing Sanctions On Those Responsible For Repression In Cuba And For Threats To United States National Security And Foreign Policy. This E.O. imposes sanctions on foreign persons or entities determined by the Secretary of State, in consultation with the Secretary of the Treasury; or by the Secretary of the Treasury, in consultation with the Secretary of State:
- to operate in or have operated in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, or any other sector of the Cuban economy, as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;
- to be owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
- to own or control, directly or indirectly, any person whose property or interests in property are blocked pursuant to this order;
- to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
- to be or have been a leader, official, senior executive officer, or member of the board of directors of the Government of Cuba or an entity whose property or interests in property are blocked pursuant to this order;
- to be a political subdivision, agency, or instrumentality of the Government of Cuba;
- to be responsible for or complicit in, or to have directly or indirectly engaged in or attempted to engage in, serious human rights abuse in Cuba;
- to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, corruption related to Cuba, including corruption by, on behalf of, or otherwise related to the Government of Cuba, or a current or former official at any level of the Government of Cuba, such as the misappropriation of public assets, expropriation of private assets for personal gain or political purposes, or bribery; or
- to be an adult family member of a person designated pursuant to this order.
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Department of State, Directorate of Defense Trade Controls (DDTC)
ITAR Ethiopia Licensing Policy Change
May 11, 2026: The Directorate of Defense Trade Controls (DDTC) posted to its website that the U.S. has terminated the arms embargo on Ethiopia. Accordingly, DDTC has removed the policy of denial for Ethiopia and is now reviewing license applications for ITAR-controlled activities involving Ethiopia on a case-by-case basis.
A forthcoming regulatory change will remove Ethiopia from the list of countries in ITAR § 126.1.
https://www.pmddtc.state.gov/ddtc_public
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End-Use Monitoring Report for FY 2025
May 26, 2026: The Directorate of Defense Trade Controls (DDTC) released its Blue Lantern and Golden Sentry, End-Use Monitoring (EUM) reports for FY2025.
The Blue Lantern program’s mission is to help ensure the security and integrity of U.S. defense trade through direct commercial sales. The program is designed to support U.S. interests by minimizing the risk of diversion and unauthorized use of U.S. defense articles or defense services to countries and other parties that aim to harm the U.S. and its allies. It combats illicit arms trafficking, uncovers security problems that can then be mitigated, and builds confidence and cooperation among defense trade partners.
Of interest:
- DTC adjudicated over 26,500 export authorization requests. Country and End-Use Analysis Division (CEA) initiated Blue Lantern checks on over 390 export authorizations or authorization requests in 82 countries.
- Several Blue Lantern checks were used to not only review specific transactions but to also analyze the management structure and security controls of foreign companies that might pose a risk of diversion of defense articles due to their acquisition or investment by a suspect foreign entity.
- CEA closed Blue Lantern checks on over 350 export authorizations or requests in FY 2025.
- 72 percent of the checks reported “favorable” results.
- 27 percent of the checks were closed as “unfavorable.”
- 1 percent of the checks were closed as “no action” due to logistical constraints that prevented Post from completing a check or changes to the original license request obviating the need for a check.
- Reasons for Unfavorable Outcome (Count).
- 55 – Refusal to cooperate
- 34 – Multiple Reasons
- 29 – Derogatory information/unreliable foreign party
- 21 – Other
- 20 – Unable to confirm order or receipt of goods
- 9 – Inability to confirm existence of foreign party
- 6 – Unauthorized reexport/retransfer
- 5 – Lack of secure storage facilities
The Golden Sentry gram EUM program is designed to provide reasonable assurance, to the extent practicable, that the recipient of goods and services received through the Foreign Military Sales program is complying with the requirements imposed by the U.S. Government with respect to the use, transfer, and security of defense articles and defense services, and that such articles and services are being used for the purposes for which they were provided.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=f7c320619774cb14fe5c39b0f053af72
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=fbc320619774cb14fe5c39b0f053af77
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May 26, 2026: DDTC published on its website the 2025 Section 655 Report. 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) 2025, in response to the requirements of Section 655(b)(3) of the Foreign Assistance Act (FAA) of 1961, as amended. Section 655(b)(3) also requires the specification of certain semiautomatic assault weapons and their spare parts, which are under the jurisdiction of the U.S. Department of Commerce; the Department of Commerce will submit a separate report regarding these items. Additionally, the U.S. Department of War will provide a separate report on International Military Education and Training activities.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=2d6361521b414b108e3086eae54bcb58
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=a56365521b414b108e3086eae54bcb72
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60-Day Notice of Proposed Information Collection: Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data
May 28, 2026: 91 Fed. Reg. 31817: The Department of State (DOS) is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, DOS is 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.
In accordance with part 123 of the International Traffic in Arms Regulations (ITAR), any person who intends to permanently export, temporarily export, or temporarily import classified defense articles, including classified technical data must first obtain Directorate of Defense Trade Controls authorization. The “Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data” (Form DSP-85) is used to obtain permission for the permanent export, temporary export, or temporary import of classified defense articles, including classified technical data, covered by the U.S. Munitions List (USML). This form is an application that, when completed and approved by the Bureau of Political Military Affairs, Directorate of Defense Trade Controls (PM/DDTC), Department of State, constitutes the official record and authorization for all classified commercial defense trade transactions, pursuant to the Arms Export Control Act and the ITAR.
DOS is soliciting public comments to permit the DOS to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
Please note that comments submitted in response to this Notice are public record. Before including any detailed personal information, you should be aware that your comments as submitted, including your personal information, will be available for public review.
The DOS will accept comments from the public up to July 27, 2026.
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DDTC Name And Address Changes Posted To Website
May 1 through May 30, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
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- Sopra Steria India Limited changed its address from Seaview Special Economic Zone, Building 4, Plot No. 20 & 21, Sector-135 Noida, Gautam Buddha Nagar, U.P. 201304, India to Institutional Plot No. B-9, Sector 132, Noida, 201304, India.
- A DSV Air & Sea Inc. entity changed its name and location due to a corporate restructuring as follows
- From: Schenker Seino Co. Ltd. located at 15/16 Tennoz Central Tower, 2-24 Higashi-Shinagawa, 2-chome 140-0002 Tokyo Japan
To: DSV Air & Sea Co. Ltd. located at 3F, 2-5-4, Fukuzumi 135-0032 Koto-Ku, Tokyo Japan
- Keysight Technologies Belgium BV changed it address from: Wingepark 51, Rotselaar, VB B-3110, Belgium to Diestsevest 32, Unit 2B, Leuven, Flemish Brabant, 3000 Belgium.
- Wytwornia Sprzetu Komunikacyjnego “PZL-Swidnik” Spolka Akcyjna changed its name to Leonardo PZL-Swidnik Spolka Akcyjna as a result of a corporate restructuring.
- Honeywell International Inc. subsidiaries that fall within Honeywell Aerospace changed their name and address as follows:
- From: Honeywell International (India) Private Limited – 1121-21, 11ith Floor, Tower A, DLF Tower, Jasola, Jasola District Centre, Delhi, New Delhi, 110025, India
To: Honeywell Aerospace India Private Limited – Campus 5A, RMZ Eco World, Marathahalli Outer Ring Road, Devarabeesanahalli, Bengaluru Urban-560102, Bengaluru, Karnataka, India
- From: Honeywell Technology Solutions Lab Pvt. Ltd. – Survey # 96 & 97 Boganahalli Village, Bangalore East, Survey#72/2 & 75/5, Doddakananahalli Village, Varthur Hobli, Karnataka, Bangalore 560 103, India
To: Honeywell Aerospace India Private Limited – Campus 5A, RMZ Eco World, Marathahalli Outer Ring Road, Devarabeesanahalli, Bengaluru Urban-560102, Bengaluru, Karnataka, India - From: Honeywell Technology Solutions Qatar – 5th Floor Amwal Tower, Dafna 61, Al Wahda Street 391, P.O. Box 63757, Doha, Qatar
To: Honeywell Aerospace Services Middle East – Office No. 1021, 10th Floor, Al Shoumoukh Tower B, Building No. 58, Suhaim bin Hamad Street, Doha, Qatar
- From: Honeywell Turki-Arabia Limited – Khobar 31952, Dhahran Techno Valley, PO Box 31916, Dhahran, Saudi Arabia
To: Honeywell Aerospace Saudi Arabia – Building No. 7682, District No. 2570, Riyadh, 13322, Saudi Arabia - From: Honeywell Middle East FZE – Office No. LB15413, P O Box 18530 Jebel Ali Free Zone, Dubai, United Arab Emirates
To: Honeywell Aerospace General Trading LLC – SOC Office 208-96, Dubai Supreme Court Complex, Umm Hurair 2, Dubai, United Arab Emirates - From: Honeywell Middle East Limited – Plot No. J-05, Honeywell Building, Abu Dhabi, Masdar, United Arab Emirates
To: Honeywell Aerospace General Trading LLC – SOC Office 208-96, Dubai Supreme Court Complex, Umm Hurair 2, Dubai, United Arab Emirates - From: Honeywell International Middle East Limited – Building 2 Level 1, Emaar Business Park Dubai, 232362 United Arab Emirates
- To: Honeywell Aerospace General Trading LLC – SOC Office 208-96, Dubai Supreme Court Complex, Umm Hurair 2, Dubai, United Arab Emirates
- ALTEN GMBH, located at Rosenauer Straβe 27, 96450 Coburg, Germany changed its address to Frankfurter Ring 81, 80807 Munich, Germany.
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
- Israel – Advanced Precision Kill Weapon System
- Philippines – Bell 505 Jet Ranger X Helicopter
- Ukraine – Joint Direct Attack Munitions – Extended Range
- Canada – C-17 Sustainment
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/05/canada-c-17-sustainment/
- Belgium – AGM-184 Joint Strike Missiles
- India – Apache Helicopters Follow-on Support
- India – Sustainment Support for M777A2 Ultra-Light Howitzers
- Republic of Korea – AH-64E Apache Upgrade Program
- Republic of Korea – MH-60R Multi-Mission Helicopters
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/05/republic-of-korea-mh-60r-multi-mission-helicopters/ - Ukraine – Hawk Missile System Sustainment
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Department of Commerce – Bureau of Industry and Security (BIS)
Guidance Regarding Enforcement of License Requirements for Advanced Computing Items for Entities Headquartered in Country Group D:5 and Macau
May 31, 2026: The Department of Commerce, Bureau of Industry and Security (BIS) issued guidance to clarify that a license is required to export advanced computing items to entities headquartered in Country Group D:5 (see supplement no. 1 to part 740 of the Export Administration Regulations (EAR) (15 CFR parts 730-774)) or Macau or with an ultimate parent company headquartered in Country Group D:5 or Macau – even if the entities themselves are located outside Country Group D:5 or Macau.
This license requirement was first introduced on November 17, 2023. It was implemented via an end-user control in § 744.23(a)(3) of the EAR and applied to all advanced computing items (e.g., those specified in Export Control Classification Numbers (ECCNs) 3A090.a and .b, 4A090.a and .b, and related .z paragraph items). In January 2025, the AI Diffusion Rule transferred the requirement for these “.a” items from § 744.23(a) into § 742.6 as part of a new worldwide license requirement. In May 2025, BIS announced that it would not be enforcing the AI Diffusion Rule’s new compliance requirements.
Recently, BIS has received questions as to whether the preexisting license requirement established in November 2023 is still being enforced for “.a” advanced computing items to Country Group D:5 and Macau-headquartered entities located outside of destinations that were subject to a license requirement prior to the AI Diffusion Rule. The answer is yes. Specifically, a license requirement continues to apply under § 742.6(a)(6)(iii)(A) of the EAR to all destinations outside the United States for these advanced computing items when such items are for entities headquartered in, or whose ultimate parent company is headquartered in, Country Group D:5 or Macau. Because this license requirement predates the AI Diffusion Rule, BIS’s non-enforcement policy with respect to the destination-based license requirements for these advanced computing items under § 742.6(a)(6)(iii)(A) applies only to the extent such items are not for entities headquartered in or that have ultimate parent companies headquartered in Country Group D:5 or Macau. Exporters should continue to seek BIS licenses for such transactions, unless a license exception specified in § 740.2(a)(9)(ii) is available.
Bona fide operators of data centers who are otherwise engaged in activities consistent with the EAR are not required to cease the ongoing use, storage, disposal, or servicing of advanced computing items because of this guidance, until further notice from BIS.
For information regarding the submission of voluntary self-disclosures, see Section 764.5 of the EAR. For guidance on the submission of license applications, see part 748 of the EAR.
https://www.bis.gov/media/documents/bis-guidance-may-31-2026.pdf
Department of Commerce – Census Bureau
Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions; Correction
May 26, 2026: 91 Fed. Reg. 30485: On August 14, 2025, the Bureau of the Census (Census Bureau) published a final rule in the Federal Register entitled “Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions”, which became effective on September 15, 2025. Subsequent review of the final rule in the Code of Federal Regulations identified errors necessitating corrective action. Accordingly, this final rule issues non-substantive corrections to the FTR.
First, this action corrects Section 30.3(a). Due to a publication error, Section 30.3(a) contains duplicative text that is already identified in the subparagraphs of that section. Second, this action corrects Section 30.6(b)(13). Due to an oversight, the text “consumption or” was inadvertently included in the second sentence during the rule writing process.
Accordingly, for the reasons stated above, 15 CFR part 30 is corrected by making the following correcting amendment:
- The authority citation for 15 CFR part 30 continues to read as follows:
Authority: 5 U.S.C. 301; 13 U.S.C. 301-307; Reorganization plan No. 5 of 1990 (3 CFR 1949-1953 Comp., p.1004); Department of Commerce Organization Order No. 35-2A, July 22, 1987, as amended and No. 35-2B, December 20, 1996, as amended; Public Law 107-228, 116 Stat. 1350.
- Amend § 30.3 by revising paragraph (a) to read as follows:
- 30.3 Electronic Export Information filer requirements, parties to export transactions, and responsibilities of parties to export transactions.
* * * * *
(a) General filer requirements.
(1) The filer of EEI for export transactions is either the USPPI or the authorized agent. If a foreign entity is the USPPI, they are prohibited from filing the EEI and must authorize an agent to file on their behalf.
(2) The filer shall maintain a physical office or residence in the United States, be physically located in the United States at the time of preparing and filing the EEI, and have an EIN or DUNS and be certified to report in the AES. If the filer does not have an EIN or DUNS, the filer must obtain an EIN from the Internal Revenue Service.
(3) All EEI submitted to the AES shall be complete, accurate, and timely. The filer is responsible for ensuring that the EEI is complete, accurate, and timely, except insofar as that party can demonstrate that it reasonably relied on information based on personal knowledge of the facts and information furnished by other responsible persons participating in the transaction. All parties involved in export transactions, including authorized agents, should be aware that invoices and other commercial documents may not necessarily contain all the information needed to prepare and file the EEI.
* * * * *
- Amend § 30.6 by revising paragraph (b)(13) to read as follows:
- 30.6 Electronic Export Information data elements.
* * * * *
(b) * * *
(13) Entry number. The entry number must be reported when goods of foreign origin enter the United States for warehousing (entered into a bonded warehouse) or are admitted into a FTZ before being exported. For goods that are exported after entering the United States for warehousing, the 11-position entry number as identified on the CBP-7501 shall be reported. For goods that are exported from a FTZ, the 9-digit inbond serial number associated with the removal shall be reported. For all other scenarios where goods are exported after entering the United States for consumption, the 11-position entry number as identified on the CBP-7501 may be reported. When the importer of record on the import entry is the customs broker or foreign person, the customs broker shall provide the entry number to assist in the preparation of the EEI (See 15 CFR 30.3(b)(2) and the Note to paragraph § 30.3(b)(2)(iv)).
Department of Justice – Bureau of Alcohol Tobacco, Firearms and Explosives (BATFE)
Update to Proscribed Countries for Import Restrictions
May 6, 2026: 91 Fed. Reg. 24387: BATFE published a proposed rule to amend Department of Justice (‘‘Department’’) regulations to remove the existing, outdated list of proscribed countries from which ATF denies applications to permanently import defense articles and services and update it to reference a Department of State list of proscribed countries. The rule also proposes to remove the list of former Soviet countries from which ATF currently denies applications to permanently import most firearms and ammunition, leaving only the Russian Federation as the proscribed country of origin for these imports.
This rule proposes to remove the current content of ATF’s regulations at 27 CFR 447.52(a) and replace it with a general statement of the U.S. policy on restricting imports from certain countries that would inform the public that ATF will base its arms import decisions on the Department of State’s policies and lists in 22 CFR 126.1. This change would ensure that the list of proscribed countries and conditions will remain consistent across Departments. It will also better inform importers of defense articles under the AECA and help ensure consistent application of foreign policy.
This rule also proposes to amend 27 CFR 447.52(b), which provides a list of countries for which all applications to permanently import firearms and ammunition manufactured or located in those countries must be denied (except for certain specifically exempted firearm models). The current list, which was added to the regulation in 1997, reflects a Department of State policy adopted after the United States entered into a Voluntary Restraint Agreement (‘‘VRA’’) with the Russian Federation in 1996. The list comprises the Russian Federation and the former Soviet countries of Georgia, Kazakhstan, Kyrgyzstan, Moldova, Turkmenistan, Ukraine, and Uzbekistan.
Thirty years later, this policy—and, by extension, the list in 447.52(b)(1)— reflects outdated trade and security concerns. Lifting these restrictions will ensure consistency with current U.S. foreign policy as directed by the Department of State, see 22 CFR 126.1(a), and allow ATF to transition from a policy of denying all requests to import firearms from certain countries to a policy that permits ATF to review license applications on a case-by-case basis. Additionally, as the terms of the VRA remain in effect, ATF will continue to restrict certain firearms and ammunition imports from the Russian Federation.
Comments must be submitted in writing on or before (or, if mailed, must be postmarked on or before) July 6, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
https://www.govinfo.gov/content/pkg/FR-2026-05-06/pdf/2026-08911.pdf
Importing Training Rounds
May 6, 2026: 91 Fed Reg 24400: BATFE published a proposed rule to amend Department of Justice (“Department”) regulations to clarify that certain training rounds do not meet the definition of “ammunition” as defined by the Gun Control Act and are not regulated by the Arms Export Control Act (“AECA”) . Less-than-lethal ammunition, which is distinct from training rounds, will still generally be considered ammunition.
BATFE’s proposal clarifies that training rounds are not “ammunition” because they are not designed to be fired from a “firearm,” as defined by the Gun Control act of 1968 (“GCA”). Although training rounds consist of cartridge cases, primers, propellant powder, and projectiles, they are not “designed for use in any firearm.”
As applicable here, the definition of “firearm” includes “any weapon (including a starter gun) which will or is designed to or may readily be converted to expel a projectile by the action of an explosive.” Although “weapon” is not further defined by the GCA or AECA, the Supreme Court in Bondi v. VanDerStok, explained that the GCA’s definition of “firearm” demonstrates congressional intent to regulate inoperable firearms and firearms capable of being readily converted to expel a projectile by the action of an explosive. The Court highlighted that the statute indicates that a starter gun is a weapon prior to any attempted conversion. Additionally, the Court explained that a “weapon,” as it pertains to the definition of firearms, is “an instrument of offensive or defensive combat.” As discussed below, training rounds are designed for use in, and are fired from, training guns, which are not “firearms” within the meaning of the GCA.
First, unlike starter guns, Congress did not expressly regulate training guns as weapons under 18 U.S.C. 921(a)(3). Moreover, training guns, unlike starter guns, are generally not capable of being readily converted to expel a projectile by the action of an explosive. Under these two aspects of the definition, training guns do not fall within the definition of “firearm.”
Second, training guns as assembled are not weapons designed for offensive or defensive combat because they are incapable of firing conventional firearm ammunition. The conversion kits used in a training gun are specifically designed so that the gun can function only with a training round that has significantly less propellant powder than conventional firearm ammunition, which allows the training round to safely and effectively cycle the conversion kit bolt. Using conventional firearm ammunition in a training gun would be unsafe. Thus, training guns are designed with additional safety features including offset firing pins to ensure they can fire only training rounds in specific calibers. In other words, the devices that fire training rounds are not “firearms” within the meaning of the GCA or the AECA.
Additionally, with respect to the training round itself, the cartridges, when discharged, produce low-energy projectiles that are designed to provide immediate feedback to a trainee during a military or law enforcement training exercise. The projectiles provide impact awareness for the shooter by providing imprint markings on the target or provide immediate non-lethal feedback to a user in close-range reality-based training scenarios often leaving bruising or welts on a person. These projectiles are not intended to cause death or serious bodily injury, nor will they likely cause such injury when used with proper safety equipment. Because they are low-energy, the projectiles are also ineffective as “less-than-lethal” ammunition in riot control situations, unlike bean bag rounds and rubber pellets that are used in weapons for nonlethal riot control. Given that these training rounds are not useful for offensive or defensive combat, they are not designed for use in instruments of offensive or defensive combat.
Moreover, based on the design of the cartridge, the training rounds themselves typically have design features consistent with use in a training device and not for use in unmodified firearms. For example, a training round for a 9mm training pistol or AR-type training rifle (or device with a conversion kit) has insufficient propellant powder to cycle a firearm’s slide or bolt. The training rounds are also not reloadable, i.e., they cannot be altered to be lethal or less-than-lethal ammunition. The cartridge case of each training round contains a plastic piston that, when removed, weakens and damages the casing so the training round cannot be reloaded without being destroyed. Nevertheless, if a manufacturer makes a “training round” that is designed for use only in a firearm, then the round may be ammunition. ATF notes that an item marketed or advertised as a “training round” would not by itself make it exempt from regulation as “ammunition.” Rather, ATF must make a determination based on an examination of the item that the round is not designed for use in offensive or defensive combat and in a firearm.
Accordingly, ATF proposes to amend the definition of “ammunition” by adding a new paragraph (c) under the existing exemptions to clarify that the term would not include “any fully assembled training round that is not designed (1) for offensive or defensive combat and (2) to be used in a device that constitutes a weapon.” Consequently, importers would not need to complete a Form 6, part I under 27 CFR parts 447 and 478 to bring training rounds into the United States.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) August 4, 2026.
https://www.govinfo.gov/content/pkg/FR-2026-05-06/pdf/2026-08914.pdf
Adding Component Definitions Under the Arms Export Control Act
May 6, 2026: 91 Fed. Reg. 24392: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) proposed amending Department of Justice (“Department”) regulations to include terms that the United States Munitions List uses to describe the composition of defense articles (“compositional terms”). Specifically, the proposed rule would amend Department regulations that implement the Arms Export Control Act (“AECA”) to define the compositional terms “component,” “accessories and attachments,” and “part” for purposes of permanent imports under the AECA.
When ATF examines importing applications that include accessories, attachments, components, or parts, ATF uses either a determination previously made by the Department of State regarding whether a defense article is an accessory, attachment, component, or part; or ATF’s Firearms and Ammunition Technology Division classifies the article relying on the ITAR definitions set forth in 22 CFR 120.40. Because ATF is guided by and largely relies on the Department of State’s views on foreign policy and matters of national security for purposes of the AECA, ATF proposes to add the compositional terms defined in 22 CFR 120.40—“accessories and attachments,” “component,” and “part”—to its AECA regulations so that ATF’s regulations include definitions for these terms and the definitions align with those in the ITAR.
Applying the ITAR’s definition of “part” to the USMIL, however, would require ATF to clarify the defense articles included under Category I—Firearms. 27 CFR 447.21. That category regulates “components and parts” but not “accessories and attachments.” 27 CFR 447.21. Yet the ITAR definition for “part” would include “any single unassembled element of a major or a minor component, accessory, or attachment. . .” 22 CFR 120.40 (emphasis added). Fully applying the ITAR definition of “part” to the USMIL Category I—Firearms would consequently lead to the result that unassembled accessories or attachments (falling under the definition of “part”) would be regulated while complete accessories or attachments would not. Therefore, ATF proposes to use paragraph (e) of Category I—Firearms, which is currently reserved, to add a sentence clarifying that “components and parts” does not include unassembled elements of an accessory or attachment. Category I—Firearms would thus include components of regulated firearms as well as unassembled elements of a component, but it would exclude assembled or unassembled attachments and accessories.
Adding the ITAR’s definitions would better inform importers of defense articles under the AECA and enable ATF to define these terms consistently when approving or denying import applications. The changes would also ensure that ATF and the Department of State align in how they use these compositional terms with respect to the USMIL and USML. And the proposed clarification within the USMIL would retain the current scope of defense articles regulated under USMIL Category I—Firearms.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) July 6, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
Export Control Reform-Conforming References to Department of Commerce
May 6, 2026, 91 Fed. Reg. 24352: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) is amending Department of Justice (“Department”) regulations to make administrative and technical clarifying revisions. These revisions add conforming references to the Department of Commerce in the relevant processes, and respond to regulatory changes already made by the Departments of Commerce and State that have effectively divided export and temporary import controls between those two agencies. The revisions also make minor technical amendments to punctuation for better clarity.
This direct final rule updates ATF’s regulatory provisions by adding references to the Department of Commerce in 27 CFR part 447 (regulations promulgated under the AECA) and 27 CFR part 479 (regulations promulgated under the NFA) to conform to the Department of Commerce’s control over certain items as a result of the ECR. More specifically, this direct final rule adds references to the Department of Commerce in the applicable sections in parts 447 and 479 to refer to those transactions that implicate the Department of Commerce’s export and temporary import jurisdiction.
- 27 CFR Part 447, Importing Arms, Ammunition, and Defense Articles
This direct final rule amends the articles-in-transit provision at 27 CFR 447.46 to add a reference to the Department of Commerce and its EAR at 15 CFR 758.10. Articles subject to 27 CFR part 447 import permit procedures that are entering the United States only temporarily pending removal, and articles temporarily taken out of the United States for subsequent return to the United States, are not considered imported or exported for part 447 purposes. Those temporary import and temporary export transactions are now subject to in transit or temporary export procedures of either the Department of State or the Department of Commerce. In addition, this rule makes a minor plain writing edit to remove the words “shall be” and “will be,” replacing the first with the word “are.”
This direct final rule also amends the exemption provisions at § 447.53(a)(3) and (b) to add references to the Department of Commerce after existing references to the Department of State. Section 447.53(a)(3) currently states that part 447 provisions do not apply to importing articles (other than firearms as defined in 18 U.S.C. 921(a)(3)) manufactured in foreign countries for persons in the United States that are subject to Department of State approval. ATF is adding “or Department of Commerce” after “Department of State” to conform to the regulatory changes made through the ECR such that the exemption applies to articles subject to either department’s approval. The provision at 27 CFR 447.53(b) currently states that any person seeking to import USMIL defense articles exempt under § 447.53(a) may obtain release of such articles from Customs custody by submitting, to the customs officer with authority to release, a statement claiming the exemption accompanied by satisfactory proof of eligibility. The proof may be in the form of a letter from the Department of Defense or State, as the case may be, confirming the person has met the exemption conditions. This direct final rule replaces “Department of Defense or State” with “Departments of Defense, State, or Commerce” in § 447.52(b).
Additionally, this direct final rule makes technical amendments to § 447.53(a)(1)-(3) to change the word “importation” to “importing” where it appears in each paragraph, and to § 447.53(a)(3) to add a missing punctuation mark, specifically to close the parenthetical phrase that ends after the citation “18 U.S.C. 921(a)(3),” and to change the term “Customs” to the term “Customs and Border Protection” and its subsequent abbreviation, to conform with that agency’s preference.
- 27 CFR Part 479, Machine Guns, Destructive Devices, and Certain Other Firearms
This direct final rule also amends the requirements at § 479.122(b), on exporting firearms caliber .22 or larger, by adding a conforming reference to the Department of Commerce—“other authorization from” in addition to the license requirement—due to Department of Commerce practices. In addition, this rule amends the requirements (1) by restructuring the last sentence to clarify up front that the person must obtain the license or authorization prior to exporting, rather than mentioning that at the end as the existing regulation does, and (2) by providing the public updated contact information for the Department of State and for the Department of Commerce regarding export authorizations.
Finally, the direct final rule adds to § 479.122(b) a new last sentence to simply remind exporters of an existing obligation, which is that they should abide by the terms and conditions of the applicable exemption or license exemption prior to exporting firearms caliber .22 or larger. This sentence reads, “Any such person should also comply with the terms and conditions of an applicable Department of State exemption or Department of Commerce license exception prior to exporting such firearms.” As described above, these changes are necessary to bring ATF’s export control regulations into conformity with changes made in March 2020 as a result of the ECR. Those changes included a split of Department of State authority over export and temporary import controls between the Department of State and the Department of Commerce, which now both control export and temporary import controls for items that are USMIL defense articles that are also controlled by ATF for permanent import purposes.
This direct final rule is effective on July 6, 2026, unless significant adverse comments are received by June 5, 2026. If ATF receives a significant adverse comment within the stated time that warrants revising the rule (as described under the “Public Participation” heading in the SUPPLEMENTARY INFORMATION section of this regulation at part IV of this preamble), ATF will publish a notice in the Federal Register withdrawing the rule before the effective date. Commenters should be aware that the https://www.regulations.gov comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
Revising Regulations Defining “Engaged in the Business” as a Dealer in Firearms
May 6, 2026: 91 Fed. Reg. 24424: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) issued a proposed rule to revise regulations implementing the “engaged in the business” definition from the Bipartisan Safer Communities Act (“BSCA”). Although Congress defined that term in BSCA, the Department of Justice (“Department”) provided additional definitions in its implementing regulations to further define terms within the statutory definition and to include examples of covered activities that established rebuttable presumptions of being engaged in the business of dealing in firearms. This rule proposes to remove those changes. ATF has determined that the changes have not shown the expected impact on federal firearms licensee applications, administrative licensing actions, civil forfeitures, or other anticipated effects.
The Department published a final rule, titled “Definition of `Engaged in the Business’ as a Firearms Dealer,” 89 FR 28968 (Apr. 19, 2024) (“EIB rule”), which became effective on May 20, 2024. The EIB rule amended the regulations in 27 CFR part 478 to (1) incorporate BSCA’s definition of the term “engaged in the business,” (2) provide clarification and guidance on what it means to be “engaged in the business” and to have the requisite intent to “predominantly earn a profit,” and (3) identify conduct that was presumed to constitute “dealing” and to show relevant intent. The EIB rule also defined the term “responsible person” and addressed the procedures former licensees must follow when they liquidate business inventory when their license is terminated.
ATF believes that the EIB rule is replete with procedural and substantive problems. Consequently, ATF proposes repealing those sections of the EIB rule that do not correctly implement the GCA and BSCA. ATF does not propose, however, to repeal the EIB rule in its entirety. Some sections of the EIB rule will be retained—for example, those providing for the discontinuance of business operations—although this rule proposes to amend some of those provisions.
ATF proposes the following regulatory changes related to the definition of engaged in the business as a dealer as implemented in §§ 478.11 and 478.13 via the EIB rule. ATF proposes to (1) move the current definition of “engaged in the business as a dealer in firearms other than a gunsmith or pawnbroker,” set forth in §§ 478.13(a) to 478.11, and (2) rescind § 478.13(b)-(h). Paragraphs (b) through (h) of § 478.13 include: (b) a statement that whether a person is engaged in the business as a dealer in firearms other than a gunsmith or a pawnbroker is a fact-specific inquiry, (c) specific fact-patterns establishing presumption that a person is engaged in the business as a dealer, (d) the definition of “predominantly earn a profit,” (e) a list of conduct that does not support a presumption, (f) evidence that may be used to rebut a presumption, (g) clarification that itemized presumptions, conduct, and rebuttal evidence are not exhaustive lists, and (h) clarification that the rebuttable presumptions do not apply to criminal proceedings.
ATF also proposes to retain the definition of “predominantly earn a profit” from § 478.13, with some revisions, and move it to § 478.11. The rest of § 478.13 would be removed, except as provided in the following paragraph. ATF is also proposing to change the definition of “personal collection” and remove the definition of “former licensee inventory,” both in § 478.11. These proposed changes are described in detail below.
ATF proposes removing all of § 478.13 except: (1) the portion of the definition of “engaged in the business as dealer in firearms other than gunsmith or pawnbroker” that duplicates statutory language in 18 U.S.C. 921(a)(21)(C); (2) the added exception for auctioneers who provide only auction services on a commission by assisting persons to liquidate firearms in an estate-type sale; and (3) a revised version of the definition of “predominantly earn a profit.” Because these remaining portions of § 478.13 would no longer be long enough to warrant a separate definition section, ATF proposes moving all three of these remaining portions from § 478.13 to § 478.11 (meaning of terms), where other relatively short definitions are located.
ATF would place the definition of engaged in the business as a dealer under paragraph (3) in the definition of “engaged in the business,” and the existing language in paragraph (3), which references § 478.13, would be removed. The paragraph would retain the same heading and would read, “A person who devotes time, attention, and labor to dealing in firearms as a regular course of trade or business to predominantly earn a profit through the repetitive purchase and resale of firearms. The term does not include a person who makes occasional sales, exchanges, or purchases of firearms to enhance a personal collection or for a hobby, or who sells all or part of the person’s personal collection of firearms.”
ATF would also move the auctioneer exception to paragraph (3) within the definition of “engaged in the business” under § 478.11, at the end of the new paragraph described above. Historically, licensees and non-licensees seeking guidance on the proper and lawful way to liquidate firearms, both in the regular course of their business or as an isolated occurrence, have commonly raised questions about auctioneers. Because ATF has regularly provided consistent guidance on what type of auction activity crosses the threshold to constitute engaging in the business of dealing in firearms, the portion of the definition that incorporates that exception into the regulation provides definitional clarity to the public and licensed community. Therefore, ATF proposes retaining the portion of § 478.13 that codifies ATF’s historical position, thus ensuring consistency for industry members. Modifying or removing this part of the definition would likely cause undue and unnecessary confusion. This proposed change would therefore add the following text to the end of paragraph (3): “In addition, the term does not include an auctioneer who provides only auction services on commission to assist in liquidating firearms at an estate-type auction, as long as the auctioneer does not purchase the firearms or take possession of the firearms for sale or consignment.”
ATF would move the text of the definition in § 478.13 of “predominantly earn a profit” to a location under the same definitional heading in § 478.11, and it would remove the text currently under that heading, which references § 478.13. It is necessary to retain this definition to distinguish between, on the one hand, what constitutes engaging in the business as a dealer in firearms other than a gunsmith or pawnbroker; and, on the other hand, engaging in the business as a gunsmith, pawnbroker, manufacturer, or importer—all of which continue to require the “principal objective of livelihood and profit” that applied to dealers prior to BSCA. The definition of “predominantly earn a profit” tracks the statutory definition; however, ATF proposes making a minor change to one sentence of the definition, so it is easier to read, without changing the meaning. Specifically, ATF proposes changing the sentence, “ Provided, that proof of profit, including the intent to profit, shall not be required as to a person who engages in the regular and repetitive purchase and disposition of firearms for criminal purposes or terrorism,” to “However, proof of profit, including the intent to profit, is not required in cases in which the person engaged in regular and repetitive purchase and disposition of firearms for criminal purposes or terrorism.” This change is in line with one of the purposes for ATF’s implementing regulations, which is to aid the public in understanding and complying with statutory provisions, and it is consistent with laws requiring plain writing. It does not modify or expand on the statutory meaning.
In addition, ATF proposes to remove the last sentence of the definition as it currently exists in § 478.13, which reads, “For purposes of this section, a person may have the intent to profit even if the person does not actually obtain the intended pecuniary gain from the sale or disposition of firearms,” because this sentence is not in the statutory definition. The proposed new definition of “predominantly earn a profit” would thus be “The intent underlying the sale or disposition of firearms is predominantly one of obtaining pecuniary gain, as opposed to other intents, such as improving or liquidating a personal firearms collection. However, proof of profit, including the intent to profit, is not required in cases in which the person engaged in the regular and repetitive purchase and disposition of firearms for criminal purposes or terrorism.”
In addition to the above changes to § 478.13, ATF proposes two changes directly to § 478.11. Specifically, for the reasons discussed in section II.A of this preamble, ATF proposes removing paragraph (1) of the definition of “personal collection (or personal collection of firearms, or personal firearms collection),” moving paragraph (2) up to replace paragraph (1) with changes necessary to conform it to regulatory paragraph designations, changing the definition’s title to reflect the remaining content, and removing the definition “former licensee inventory” entirely. The proposed heading for the definition of “personal collection (or personal collection of firearms, or personal firearms collection)” would instead be “licensee personal collection (or personal collection of licensee).” The rest of the definitional text would remain the same as currently in § 478.13, but the paragraph designation would change because it would no longer be paragraph (2).
In addition, the rule proposes to make changes to § 478.57 (Discontinuance of business). The proposed rule would remove from paragraphs § 478.57(b)(2) and (c) the relevant sentences that effectively restrict former licensees from reselling their firearms without being presumed to be engaged in the business. Specifically, it would remove from § 478.57(b)(2) the sentence that reads: “Any such transfer, however, does not negate the fact that the firearms were repetitively purchased, and were purchased with the predominant intent to earn a profit by repetitive purchase and resale.” And it would remove from § 478.57(c) the second sentence that provides that a former FFL who resells any of its former business inventory is subject to the provisions of § 478.13. Because this rule proposes to remove § 478.13, the provisions in these paragraphs would no longer be relevant. And because these provisions are also found in § 478.78 (Operations by licensee after notice), this rule proposes to remove from § 478.78(b)(2) and (c) the same sentences.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) August 4, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
Converting Temporary to Permanent Imports for Defense Articles
May 8, 2026: 91 Fed. Reg. 25159: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) issued a proposed rule to amend Department of Justice (“Department”) regulations regarding the permanent import provisions of the Arms Export Control Act (“AECA”). The proposed rule would allow importers to apply for ATF authorization to convert items imported temporarily—under a Department of State (“DOS”) authorization or under the entry clearance requirements for temporary imports in the Export Administration Regulations (“EAR”) maintained by the Department of Commerce (“DOC”)—to permanent imports in compliance with other applicable federal firearms laws, without having to export and then reimport the items.
ATF proposes amending the definition of “Import or importation” in 27 CFR 447.11 to indicate that importing ( i.e., permanently importing) occurs not only when an article is brought into the United States as a permanent import, but also when an article, lawfully in the United States pursuant to a DOS authorization or pursuant to meeting DOC’s entry clearance requirements for temporary imports under 15 CFR 758.10, is converted to remain in the United States permanently before the DOS authorization expires or while still in compliance with 15 CFR 758.10 entry clearance requirements. This proposed change to the definition would permit ATF to process a Form 6, part I, for items currently in the United States as temporary imports and, if otherwise authorized by law, permit the importer to convert these articles to permanent imports. This would establish a clear process by which importers could avoid unnecessary costs while ensuring that such imports remain subject to ATF review and are in compliance with federal law. Temporary imports of ITAR defense articles subject to DOS authorization or defense articles subject to DOC EAR clearance requirements would also remain subject to ITAR or EAR jurisdiction until DOS or DOC, respectively, recognizes a change in end user or end use.
ATF also proposes amending 27 CFR 447.42 by adding a new paragraph (c), which would provide a process through which an importer can apply to convert a temporarily imported item to a permanently imported one by submitting a Form 6, part I, to ATF for approval. Specifically, this rule would require importers to indicate on Form 6, part I, that they intend to convert the temporarily imported item to a permanently imported one and to submit with it a copy of the DSP-61 issued by DOS, entry documents showing that they claimed an ITAR exemption, or a copy of the temporary import entry clearance documents provided to CBP pursuant to DOC’s entry clearance requirements. This would eliminate a potentially wasteful regulatory barrier without negatively impacting public safety or otherwise permitting importers to circumvent statutory importing restrictions.
Because neither the GCA nor the NFA exempts temporarily imported items pursuant to DOS authorization or DOC clearance requirements from their definition, such temporary imports must comply with GCA and NFA restrictions and their implementing regulations at parts 478 and 479, just as permanent imports must. As a result, this rule does not propose any changes to those regulatory provisions. By proposing to add the requirement to submit a Form 6, part I, application for ATF approval when converting, this rule would ensure compliance with the AECA as well. Under the existing regulation at 27 CFR 447.44, ATF has the authority to deny applications for AECA import permits—which would include the conversion applications proposed in this rule—when importing as requested would be “inconsistent with the purpose or in violation of” the AECA or its implementing regulations in 27 CFR part 447. Additionally, ATF would deny applications if the conversion does not comply with the import provisions of the GCA and NFA.
Moreover, ATF proposes to amend 27 CFR 478.112 by adding a new paragraph (e) to clarify the marking requirements for firearms converted to permanently imported items under this process. Currently, § 478.112 requires that importers comply with marking requirements within 15 days after CBP releases the firearms from its custody. However, this time period does not work in the case of temporary-to-permanent conversions because the items are not in CBP custody once they have been imported as temporary items and released. So, in the case of temporary imports, items may have been exempt from the GCA or NFA marking requirements and might not be marked at the time the items are released from CBP custody—and thus might not be marked at the time the importer wants to convert them to permanent imports. The amendment to § 478.112(e) would provide that, in such cases, the importer must ensure converted items are marked as required by the GCA and NFA within 15 days after ATF approves a Form 6, part I, to convert them from temporarily imported items to permanently imported ones. In addition, the new paragraph would include a requirement that the importer also submit a Form 6A to ATF within that same timeframe, to reflect that these items are being converted to permanent imports, and to record their serial numbers, as required for items imported on a permanent basis in the first instance.
ATF is also proposing minor plain writing and other technical amendments to §§ 447.11, 447.42 (particularly in paragraphs (a) and (b), which have no substantive changes), 478.11, and 478.112 (particularly in paragraphs (a)-(d), which have no substantive changes) to make the definitions and instructions easier to read, including using the term “importing” instead of “importation,” reducing passive voice, substituting “U.S. Customs and Border Protection” and “CBP” thereafter for “Customs,” and updating headings and form numbers and names.
ATF also notes that other non-conflicting changes to §§ 478.11 and 479.11 are being proposed in a separate notice of proposed rulemaking to amend the definition of “importation” as it pertains to foreign trade zones and custom bonded warehouses.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) August 6, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
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
Four Defendants Convicted in Plot to Kill Haitian President Jovenel Moïse
A federal jury in Miami today convicted four defendants for their roles in the July 7, 2021, assassination of Haitian President Jovenel Moïse.
Arcangel Pretel Ortiz, Antonio Intriago, Walter Veintemilla, and James Solages were convicted of conspiracy to provide material support or resources to carry out a violation of 18 U.S.C. § 956, resulting in death; providing material support and resources to carry out a violation of 18 U.S.C. § 956, resulting in death; conspiracy to kill and kidnap a person outside the United States; conspiracy to commit offenses against the United States; and expedition against a friendly nation. Intriago was also convicted of a third count of conspiracy to commit offenses against the U.S.; smuggling goods from the U.S.; and submitting false or misleading export information.
“This case exposed a far-reaching criminal conspiracy driven by power, profit, and political ambition that extended well beyond Haiti’s borders,” said Acting Special Agent in Charge Jose R. Figueroa of Homeland Security Investigations (HSI) Miami. “HSI and our partners followed the evidence across jurisdictions and international boundaries to help hold accountable those responsible for this heinous plot to assassinate a sitting president and destabilize a partner nation.”
Veintemilla played a central role in financing the conspiracy. Starting in April 2021, Veintemilla agreed to finance the scheme through a $175,000 loan agreement financed with proceeds derived from others’ Coronavirus Aid, Relief, and Economic Security (CARES) Act’s Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL) funds that were funneled through an account controlled by a co-conspirator. Trial evidence also showed that Veintemilla was involved in the operational details. After learning of the assassination in the early morning hours of July 7, 2021, Veintemilla immediately called a co-conspirator and proclaimed: “the rat (President Moïse) is in the box.”
Pretel Ortiz, who referred to himself as “Colonel Gabriel” and routinely wore fake U.S. military-style uniforms, rank, and insignia, directed the plot’s tactical planning and operation, including coordinating with the Colombian mercenaries. Hours before the assassination, Pretel Ortiz told his co-defendants: “I put my men on the ground and we are still fighting to reach the objective.”
Intriago, Pretel Ortiz’s business partner, handled the day-to-day logistical aspects of the plot, including payroll, equipment, and provisions for the co-conspirators. On June 10, 2021, Intriago helped smuggle bulletproof vests and other tactical equipment—including radios, flashlights, and goggles—from Miami to Haiti for use by the Colombian mercenaries during the assassination. In late June 2021, Intriago traveled to Haiti and photographed himself with the group’s Haitian allies. On the eve of the assassination, Intriago messaged his co-conspirators: “We finally got the tools to do the work.”
Solages served as the defendants’ primary liaison in Haiti and repeatedly traveled between South Florida and Haiti to coordinate with Haitian gang leaders, obtain weapons and ammunition in Haiti, and conduct surveillance of President Moïse’s residence. Solages also accompanied the Colombian mercenaries during the attack and instructed them to kill everyone inside the house, including “the dog, the cat, and parrot.”
All four defendants face maximum penalties of life in prison. U.S. District Judge Jacqueline Becerra for the Southern District of Florida will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.
FBI Miami and HSI Miami investigated the case, with valuable assistance from the Department of State; the Bureau of Alcohol, Tobacco, Firearms and Explosives; the U.S. Department of Commerce, Bureau of Industry and Security, Office of Export Enforcement; and the Department of Defense Criminal Investigative Service.
https://www.justice.gov/opa/pr/four-defendants-convicted-plot-kill-haitian-president-jovenel-moise
Arcadia, California, Mayor Federally Charged with Acting as Illegal Agent of the People’s Republic of China
May 11, 2026: The Department of Justice announced the mayor of Arcadia, California, has been charged in federal court with acting as an illegal agent of the People’s Republic of China (PRC), the Justice Department announced today.
Wang was elected in November 2022 to the Arcadia City Council, a five-person governing body from which the mayor is selected on a rotating basis.
“By her own admission, Eileen Wang secretly served the interests of the Chinese government,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “Let this serve as a clear warning: individuals who act on behalf of foreign governments to influence our democracy will be identified, investigated, and brought to justice. Protecting the rule of law and the transparency of our democratic process remains at the core of the FBI’s mission, and we will continue working alongside our partners to safeguard the integrity of our elections and keep hostile actors from undermining the voices of the American people.”
According to her plea agreement, from late 2020 through 2022, Wang and Yaoning “Mike” Sun, 65, of Chino Hills, California, worked at the direction and control of PRC government officials and coordinated with U.S.-based individuals to promote the PRC’s interests by, among other things, promoting pro-PRC propaganda in the United States. Sun is serving a four-year federal prison sentence after he pleaded guilty in October 2025 to acting as an illegal agent of a foreign government.
Wang and Sun worked together to operate U.S. News Center, a website that purported to be a news source for the local Chinese American community. Wang and Sun received and executed directives from PRC government officials to post pro-PRC content on the website.
In a related filing, Wang has agreed to plead guilty to the felony count, which comes with a maximum penalty of 10 years in prison
Luxury Yacht Companies Plead Guilty to Violating Lacey Act for Using Illegally Obtained Burmese Teak on Multimillion Dollar Yachts; Agree to Pay $200,000 Fine
May 13, 2026: The Department of Justice announced Sunseeker International Limited and Sunseeker USA Sales Co. Inc. (Sunseeker) pleaded guilty to two violations of the Lacey Act for using illegally obtained Burmese Teak on yachts that it imported into the United States. Sunseeker agreed to pay a fine of $200,000, and to implement a compliance plan, among other penalties. Sunseeker manufactures luxury performance motor yachts and superyachts.
Sunseeker manufactures its vessels in the United Kingdom (U.K.) and sells them internationally, including in the United States. Sunseeker pleaded guilty to using Burmese Teak on their yachts, specifically, a Teak balcony door intended to be incorporated into a yacht, and Teak parts incorporated into two yachts priced at approximately $2.98 million and $1.07 million, respectively.
The illegal logging of Teak in Myanmar has been a known problem since at least 2017. Both the U.S. and the U.K. have imposed sanctions against Myanmar and the U.S. has sanctioned the Myanma Timber Enterprise (MTE), the sole authorized seller of export Teak harvested in Myanmar. U.S. sanctions prohibit all transactions by U.S. persons or those transiting the U.S. that involve any property or interest in property associated with the MTE. The U.K. has concluded that timber harvesting, specifically Teak, has financially supported dictatorships in Myanmar.
Sunseeker was previously charged in the U.K. and pleaded guilty in 2023 to three criminal violations of the U.K.’s Timber and Timber Products Regulations (UKTR). The company was sentenced and fined approximately $450,000. The Teak imports that Sunseeker imported into the U.S. came from the illegal Teak imports charged in the U.K. case.
Homeland Security Task Force Arrests Maduro Regime Ally Alex Saab on Money Laundering Charges Involving Venezuelan Food Contracts and Oil
May 18, 2026: The Department of Justic announced the indictment of Alex Nain Saab Moran, 55, a Colombian national and Venezuela’s former Ministry of Industry and National Production, who allegedly conspired with others to bribe Venezuelan public officials to secure lucrative Comité Local de Abastecimiento y Producción (CLAP) contracts to import food into Venezuela. Saab is accused of conspiring with others to fraudulently misrepresent the nature and source of the food supplies, including falsely documenting imports from Colombia and Mexico.
“This indictment alleges that a humanitarian food program intended to support vulnerable Venezuelans was instead manipulated for massive personal enrichment,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “According to the charges, the defendant used bribery, shell companies, and fraudulent documents to siphon hundreds of millions of dollars for personal gain. When illicit proceeds are moved through the United States financial system, our courts have jurisdiction and our prosecutors will act. The charges are allegations, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt.”
Rather than fulfilling the contracts, Saab and his co-conspirators secretly used shell companies, fraudulent invoices, falsified shipping records, and other fabricated documents — along with a network of bribes and kickbacks — to siphon off hundreds of millions of dollars that were intended to be used to purchase food for needy Venezuelans. Portions of the illicit proceeds were allegedly spent or concealed through transfers to and through bank accounts in the U.S.
The indictment further alleges that, from 2019 through at least January 2026, the conspiracy expanded as U.S. economic sanctions crippled Venezuelan exports, especially oil, placing severe strain on the country’s finances and its ability to meet its foreign debt obligations, including payments to Saab and his co-conspirators as part of the CLAP program. Exploiting their corrupt relationships with government officials, Saab and his co-conspirators allegedly gained access to billions of dollars’ worth of oil owned by Venezuelan state-owned Petróleos de Venezuela, S.A. (PDVSA) and sold it under false pretenses.
Proceeds from those illegal sales were then transferred to and through U.S. bank accounts to further promote and conceal the CLAP scheme.
Saab is charged with conspiracy to launder monetary instruments. If convicted, he faces a maximum penalty of 20 years in federal prison.
Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Adani Enterprises Limited
May 18, 2026: The Office of Foreign Assets Control (OFAC) announced a $275,000,000 settlement with Adani Enterprises Limited (AEL), an Ahmedabad, India-based company. AEL agreed to settle its potential civil liability for 32 apparent violations of OFAC’s Iran sanctions. From November 2023 to June 2025, AEL purchased shipments of liquified petroleum gas (LPG) from a Dubai-based trader purporting to supply Omani and Iraqi gas.
AEL acted recklessly by ignoring red flags point to potential links to Iran. These included warnings received from third parties that LPG cargos being imported by AEL may have been of Iranian-origin, and the economic, commercial, and logistical implausibility of the cargos’ origin and pricing. AEL also did not conduct additional due diligence that may have revealed that the vessels carrying its LPG cargos routinely engaged in suspicious behavior such as Automatic Identification System manipulation, uneconomic or illogical vessel movements or port calls, and frequent name, ownership, and flag state changes.
During this time period, AEL caused U.S. financial institutions to process 32 U.S. dollar denominated payments totaling approximately $192,104,044 for the shipments. The settlement amount reflects OFAC’s determination that AEL’s apparent violations were egregious and not voluntarily self-disclosed and further reflects the AEL’s remedial measures following discovery of the conduct and the cooperation AEL provided for OFAC’s investigation
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=fbc320619774cb14fe5c39b0f053af77
https://ofac.treasury.gov/media/935636/download?inline https://ofac.treasury.gov/media/935631/download?inline
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Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for May 1 through May 31, 2026.
- Iran-related Designations; Issuance of Iran-related General License and Frequently Asked Question; Publication of Iran-related OFAC Alert
https://ofac.treasury.gov/recent-actions/20260501
- Issuance of Executive Order Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security And Foreign Policy
https://ofac.treasury.gov/recent-actions/20260501_33
- Issuance of Venezuela-related General License and Amended Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260504
- Issuance of Venezuela-related General License
https://ofac.treasury.gov/recent-actions/20260505
- Counter Terrorism and Iran-related Designations; Cuba Designation and Designations Updates; Issuance of Cuba-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260507
- Counter Terrorism and Counter Narcotics Designation Update, Russia-related Designation Removal
https://ofac.treasury.gov/recent-actions/20260508
- Non-Proliferation and Iran-related Designations and Designations Updates
https://ofac.treasury.gov/recent-actions/20260508_33
- Counter Terrorism Designations; Iran-related Designations
https://ofac.treasury.gov/recent-actions/20260511
- Notice with Regard to International Criminal Court-related Sanction
https://ofac.treasury.gov/recent-actions/20260515
- Cuba Designations and Designations Updates; Issuance of Russia-related General License
https://ofac.treasury.gov/recent-actions/20260518_33
- Counter Terrorism Designations; Iran-related Designations
https://ofac.treasury.gov/recent-actions/20260519
- Counter Narcotics and Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260520
- International Criminal Court-related Designation Removal
https://ofac.treasury.gov/recent-actions/20260520_33
- Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260521
- International Criminal Court-related Designation
https://ofac.treasury.gov/recent-actions/20260527 - Iran-related Designation; Counter Terrorism Designation
https://ofac.treasury.gov/recent-actions/20260527_33 - Iran-related Designations; Issuance of Russia-related General License and Amended Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260528_33
Counter Terrorism Designations; Issuance of Amended Iran-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260529
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE MAY 2026 Read More »
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE APRIL 2026
This newsletter is a listing of the latest changes in export control regulations through April 30, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
REGULATORY UPDATES
President
Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Domestic Petroleum Production, Refining, and Logistics Capacity
April 20, 2026: 91 Fed Reg. 21933: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) domestic petroleum production, refining, and logistics capacity, including exploration and production, gathering and transmission pipelines, storage, and marine terminals, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology item in a timely manner due to constrained financing, long lead times, permitting and infrastructure bottlenecks, and supply chain limitations; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand the domestic petroleum production, refining, and logistics capacity is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08016.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Coal Supply Chains and Baseload Power Generation Capacity
April 20, 2026: 91 Fed. Reg. 21927: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) coal supply chains and baseload power generation capacity, including coal mining, rail and barge logistics, export and domestic terminals, generating unit availability and life-extension work, on-site stockpiles, and associated reliability updates, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology item in a timely manner due to financing constraints, regulatory delays, long-lead maintenance, expensive and bespoke repair cycles, and market barriers; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand coal supply chain capacity and baseload generation availability is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08010.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Natural Gas Transmission, Processing, Storage, and Liquefied Natural Gas Capacity
April 20, 2026: 91 Fed. Reg. 21935: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) natural gas and LNG capacity, including gathering and transmission pipelines, compression, processing plants, underground storage, LNG liquefaction, storage and marine load, export facilities, and critical distribution infrastructure, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology item in a timely manner due to financing constraints, long-lead equipment and construction schedules, permitting delays, and infrastructure bottlenecks; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand domestic natural gas transmission, processing, storage, and LNG capacity is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08017.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Development, Manufacturing, and Deployment of Large-Scale Energy and Energy Related Infrastructure
April 20, 2026: 91 Fed. Reg. 21929: The President determine, pursuant to section 303(a)(5) of the Act, that:
(1) development, manufacturing, and deployment of large-scale energy and energy-related infrastructure, including engineering, site acquisition and preparation, permitting, early-stage risk mitigation financing instruments, domestic manufacturing capacity, and enabling infrastructure, are industrial resources, materials, and critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology items in a timely manner due to financing risks, regulatory delays, and market barriers; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determined that action to expand the domestic capability to undertake development, manufacturing, and deployment of large-scale energy and energy-related infrastructure is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, the President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08011.pdf
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Presidential Determination Pursuant to Section 303 of the Defense Production Act of 1950, as Amended, on Grid Infrastructure, Equipment, and Supply Chain Capacity
April 20, 2026: 91 Fed. Reg. 21931: The President determined, pursuant to section 303(a)(5) of the Act, that:
(1) grid infrastructure and its associated upstream supply chains, including transformers, transmission lines and conductors, substations, high-voltage circuit breakers, power control electronics, protective relay systems, capacitor banks, electrical core steel, and related raw materials and manufacturing tools, are industrial resources, materials, or critical technology items essential to the national defense;
(2) without Presidential action under section 303 of the Act, United States industry cannot reasonably be expected to provide these capabilities for the needed industrial resource, material, or critical technology items in a timely manner due to limited domestic production capacity, extended procurement timelines, foreign supply dependence, and insufficient capital investment; and
(3) purchases, purchase commitments, financial support for the development of production capabilities, or other action pursuant to section 303 of the Act are the most cost-effective, expedient, and practical alternative methods for meeting this need.
The President declared a national emergency under Executive Order 14156, and further determine that action to expand the domestic capability to develop, manufacture, and deploy grid infrastructure and supporting industrial supply chains is necessary to avert an industrial resource or critical technology item shortfall that would severely impair national defense capability. Therefore, pursuant to section 303(a)(7) of the Act, The President waived the requirements of section 303(a)(1)-(a)(6) of the Act for the purpose of expanding such capability.
https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-08013.pdf
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Department of State, Directorate of Defense Trade Controls (DDTC)
60-Day Notice of Proposed Information Collection: Brokering Prior Approval (License)
April 6, 2026: 91 Fed. Reg. 17323: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collection to OMB.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=64ac35fc971c07580083b3b0f053af56
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60-Day Notice of Proposed Information Collection: Annual Brokering Report
April 6, 2026: 91 Fed. Reg. 17324: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the
collection to OMB.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=e4acb1fc971c07580083b3b0f053af6b
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60-Day Notice of Proposed Information Collection: Disclosure of Violations of the Arms Export Control Act
April 7, 2026: 91 Fed. Reg. 17669: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=64ac35fc971c07580083b3b0f053af5a
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IMPORTANT: DECCS Registration Enhancements April 30, 2026
April 27, 2026: DDTC updated the DECCS Registration application on Wednesday, April 30, 2026 and introduced new features including:
- Enhanced validation for articles and documents
- Improved management of senior officers and points of contact
- Better compliance tracking
- Additional safeguards to prevent accidental amendment submissions
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DDTC Name And Address Changes Posted To Website
April 1, 2026, through April 30, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Honeywell International Inc. subsidiaries that fall within the Honeywell Aerospace Technologies division changed their name and address due to corporate restructuring.
- From: Honeywell Limited / Honeywell Limitee Address: 3333 Unity Drive, Mississauga, Ontario L5L 3S6 Canada
To: Honeywell Aerospace International Inc. Address: 3333 Unity Drive, Mississauga, Ontario L5L 3S6 Canada
- From: Honeywell Limited Address: Level 2, 2 Richardson Place North Ryde, NSW 2113, Australia
To: Honeywell Aerospace Australia Pty. Ltd. Address: Suite 301A, 25 Montpelier Road, Bowen Hills, Queensland 4006 Australia - From: Honeywell do Brasil Ltda. Address: Avenida Tambore, 267, Edificio Canopus Corporate Alphaville, 16 e 17 andares, Sao Paulo, Barueri, CEP –6460-000 Brazil
To: Honeywell Aeroespacial do Brasil Ltda. Address: Avenida Brigadeiro Faria Lima, 2170, salas 16, 17 e 18. Predio F-65, Sao Paulo State, Jao Jose dos Campos City, Brazil - From: Honeywell Chile S.A. Address: El Bosque 500, 8th Floor, Las Condes, Santiago Chile
To: Honeywell Aerospacial Chile S.p.A Address: Avenida el Bosque Norte 500 Piso 8, RM, Santiago, 750-0007, Chile - From: Honeywell Colombia S.A.S. Address: Carrera 11, #98-50, Edifico Punto 99, Piso 7, Bogota, Capital District, Colombia
To: Honeywell Aerospace Colombia S.A.S. Address: Carrera 11, #98-50, Edifico Punto 99, Piso 7, Bogota, Capital District, Colombia
- From: Honeywell spol. S.r.o. Address: V Parku 2325/16, Praha, 14800, Czech Republic
To: Honeywell International s.r.o. Address: V Parku 2325/16, Praha, 14800, Czech Republic
- From: PT Honeywell Indonesia Address: 24th Floor Menara Prima, Unit E, Jl. Dr. Ide Anak Agung Gde Agung Blok 6.2, Kawasan Mega Kuningan, Jakarta, 12950, Indonesia
To: PT Honeywell Aerospace Indonesia Address: Sopo Del Tower B, 22nd Floor, JL. Mega Kuningan Barat III Lot 10. 1-6, Kuningan, South Jakarta, Jakarta 12950 - From: Japan Honeywell GK Address: 16-1, Kaigan 1-chome, Minato-ku, Tokyo, Japan, 105-0022, Tokyo, Japan
To: Honeywell Aerospace Japan GK Address: 1-6, Motoazabu 3-chome, Minatoku, Tokyo, Japan
- From: Honeywell International Sdn. Bhd. Address: Level 25, UOA Corp Tower Lobby B, Avenue 10, The Vertical, Bangsar South City, Kuala Lumpur, 59200, Malaysia
To: Honeywell Aerospace Malaysia Sdn. Bhd. Address: Suite 1005, 10th Floor, Wisma Hamzah Keonh Hing, No. 1 Leboh Ampang 50100 Kuala Lumpur W.P. Kuala Lumpur Malaysia
- From: Honeywell Automotive de Mexico S. de R. L. de C.V. Address: Av Salvador Nava Martinez 3125, Piso 6 Colinas Del Parque, San Luis Potosi, San Luis Potosi, 78260, Mexico
To: Honeywell Aerospace de México, S. de R.L. de C.V. Address: Circuito Aeroespacial Lote 2, Parque Industrial El Vigia, Mexicali, Baja California, 21397, Mexico - From: Honeywell Sp. Z.o.o. Address: Domaniewska 39, Warsaw, 02672, Poland
To: Honeywell Services Poland Sp Z.o.o. Address: ul. Zelazna 4, Katowice, 40-851, Poland - From: Honeywell S.L. Address: María de Portugal, 1-5, Building 3, Madrid, 28050, Spain
To: Honeywell Aerospace Spain S.L. Address: 39, Paseo de la Castellana, Madrid, 28046, Spain - From: Honeywell Taiwan Limited Address: 5F, No.3, Yuandong Road, Banqiao District, New Taipei City, Taiwan (Province of China)
To: Honeywell Aerospace Taiwan Ltd Address: 8F. No.560 Sec.4 Zhongxiao E. Rd. Xinyi Dist. Taipei City 110 Taiwan(R.O.C.)
- From: Honeywell Teknoloji Anonim Sirketi Address: Küçükbakkalköy Mah., Kayisdagi Ca d. No:1, Allianz Plaza Kat:27, Atasehir, Istanbul, 34750, Turkey
To: Honeywell Aerospace Turkey Havacılık ve Uzay Sanayii Limite d Sirketi Address: Şirketi Allianz Plaza Sitesi D:27, Kucukbakkalkoy Mah. Kayisdagi Cad, No:1, Allianz Plaza Kat:27 Atasehir, Istanbul, 34751, Turkey
- MDA Systems Ltd. changed its name to MDA Space 49North Ltd. due to a corporate restructuring.
- Keysight Technologies Denmark ApS changed its address from Alfred Nobels VEJ 21, Aalborg East 9220, Denmark to Alfred Nobels VEJ 21F, Aalborg East DK-9220 Denmark.
- Enterprise Services Defence and Security UK Ltd., Entserv UK Limited, and ES Field Delivery UK Limited (collectively referred to as “DXC UK entities”) changed their address as follows: DXC UK entities, Royal Pavillion, Wellesley Road, Aldershot, United Kingdom GU11 1PZ to 110 Pinehurst Road, Farnborough Business Park, Farnborough, United Kingdom, GU14 7BF.
- Computer Sciences Limited was added to DXC UK entities as a new subsidiary
- ispace, inc. changed its address from Sumitomo Fudosan Hamacho Building 3F, 3-42-3 Nihonbashi Honcho, Chuo-ku, Tokyo, Japan 103-0007 to Nihonbashi Honcho M-SQUARE 6F, 1-9-3 Nihonbashi Honcho, Chuo-ku, Tokyo, Japan 103- 0023.
- Metrea Management, LLC’s Swedish and Australian affiliates changed their addresses due to corporate restructuring.
- Metrea Simulations AB, Sweden
From: Luntmakargatan 66, 113 51 Stockholm, Sweden
To: Luntmakargatan 34, 111 37, Stockholm, Sweden
- Metrea Australia Solution 1 Pty Ltd and Metrea Australia Assets Pty 1 Ltd Metrea Australia Pty Ltd
From: Director’s Vault 6/46 Washington Street, Toorak Victoria, Australia
To: Suite 2.03, Part Level 2, 220 St George Terrace, Perth WA, 6000, Australia
- MDA Systems Ltd. transferred its’ business to MDA Space 49North Ltd., a separate, wholly-owned subsidiary of MDA Systems Ltd, due to corporate restructuring.
- Wescam USA, Inc. changed its address from 2410 North Orange Blossom Trail, Orlando, FL 32804 to 2204 Charlotte Ave., Building C, Nashville, TN 37203.
- Pacific Aerospace Consulting Pty Ltd (PAC) was acquired by Aurizn Bidco Pty Ltd, wholly owned by Aurizn Holdco Pty Ltd, and changed its address from Suite 111, 460 Pacific Highway, St Leonards NSW 2065 Australia to U2.02 Building E, 1 Technology Place, Willamtown NSW 2318 Australia
- Maxar Intelligence Inc., selected affiliates and foreign subsidiaries, changed their names due to a corporate split and rebranding as follows:
- From Maxar Technologies Inc. to Vantor Parent Inc.;
- From Maxar Technologies Holdings Inc. to Vantor Holdings Inc.;
- From Maxar Intelligence Inc. to Vantor Inc.;
- From Maxar International Inc. to Vantor International Inc.;
- From Maxar Mission Solutions Holdings Inc. to Vantor Services Holdings Inc.;
- Maxar Mission Solutions Inc. to Vantor Services Inc.;
- From Maxar Intelligence 3D Inc. to Vantor 3D Inc.;
- From Wovenware Inc. to Vantor Puerto Rico Inc.;
- From Maxar International Canada Inc. to Vantor Canada Inc.;
- From Maxar International Australia Pty Inc. to Vantor Australia Pty Ltd.;
- From Maxar International Asia Pacific Pte. Ltd. to Vantor Asia Pacific Pte. Ltd.; and
- From Maxar International Great Britain Limited to Vantor Great Britain Limited
- CEVA Freight LLC located at 15350 Vickery Dr., Houston, Texas 77032-2530 transferred its’ business to CEVA Air & Ocean USA Inc. located at 1412 Broadway Ste 402, New York, New York 10018.
Editors practice tip: freight forwarder changes such as noted herein may impact your export license. As with this change and any noted in the DDTC website for name and address changes be sure to include a copy of the DDTC notice which can be pulled down from the attached link with your export license when providing the license to the freight forwarder.
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
- Singapore – Guided Multiple Launch Rocket System – Alternative Warhead
https://www.state.gov/singapore-guided-multiple-launch-rocket-system-alternative-warhead/
- Germany- Integrated Combat System, Supporting Equipment, and Support
- The Netherlands – Hellfire Missiles
- Lithuania – AIM-9X Sidewinder Block II Missiles
- Tunisia – Border Security Project Phase III
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Department of Commerce – Bureau of Industry and Security (BIS)
BIS published a rule titled “Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits; Amendments and Clarifications; and Extension of Comment Period”
April 9, 2026: 91 Fed. Reg. 17851: On January 16, 2025, BIS published a rule titled “Implementation of Additional Due Diligence Measures for Advanced Computing Integrated Circuits; Amendments and Clarifications; and Extension of Comment Period”, which included a timeline during which certain companies are considered authorized integrated circuit (IC) designers who can overcome a presumption of certain license requirements. On April 7, 2026, BIS extended this timeline until December 31, 2026. This extension will allow more time for companies to submit Approved IC Designer applications and allow BIS additional time to process these applications.
https://www.govinfo.gov/content/pkg/FR-2026-04-09/pdf/2026-06851.pdf
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American AI Exports Program; Call for Proposals for Pre-Set Consortia
April 10, 2026: 91 Fed. Reg. 18412: The Department of Commerce, International Trade Administration invites proposals for full-stack American AI export packages from industry-led `pre-set’ consortia for designation under the American Artificial Intelligence (AI) Exports Program (the Program) established pursuant to Executive Order 14320, “Promoting the Export of the American AI Technology Stack.” A designated package will be presented by U.S. Government representatives as a standing, full-stack American AI export package and may receive priority government advocacy, export licensing review and processing, interagency coordination, and financing referrals, subject to applicable law. Designation does not guarantee any particular form of federal assistance, financing, license approval, advocacy outcomes, or a contract award.
The call for proposals opens on April 1, 2026 and proposals will be accepted until 5:00 p.m. Eastern Daylight Time on June 30, 2026.
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Eliminating Outdated Regulation Related to Reports on Exports of Technology
April 17, 2026: 91 Fed. Reg. 20582: The Department of Commerce eliminated 15 CFR Part 1300, an outdated regulation related to reports on exports of technology. The cited statutory basis for the regulation has been repealed, and its contents are plainly obsolete and pose a genuine risk of confusion. This action is necessary to ensure that the Department’s body of regulations remains accurate, up-to-date, and in conformity with statutory law.
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
March 27, 2026: The Department of Commerce’s Bureau of Industry & Security (“BIS”) reached a settlement with Solventum Corporation, under which the company agreed to pay $1,600,000 for two violations of the EAR.
The two violations involved the unlicensed exports of EAR99 Liqui-Cel Membrane Contactors (“Contactors”) to Semiconductor Manufacturing South China Corporation (“SMIC South”) and Ningbo Semiconductor International Corporation (“NSI”). Both companies are identified on the Entity List and required a license for the export, reexport, or transfer (in-country) for all items subject to the EAR.
https://www.bis.gov/media/documents/settlement-agreement-solventum.pdf
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April 8, 2026: The Department of Justice announced the arrest of Courtney Williams, a former Army employee, and a federal grand jury indictment in connection with her alleged transmission of classified national defense information to individuals not authorized to receive it, including a journalist (the Journalist). Williams allegedly violated 18 U.S.C. § 793(d).
From 2010 to 2016, Williams worked for a Special Military Unit (SMU) and held a Top Secret / Sensitive Compartmented Information security clearance. In her role at the SMU, Williams had daily access to a broad range of classified information.
Between 2022 and 2025, Williams repeatedly communicated with a journalist via telephone and text messages. During this period, Williams and the journalist had over 10 hours of telephone calls and exchanged more than 180 messages. In one such message, the Journalist identified themselves as a journalist and stated that they sought information about the SMU in support of an upcoming article and book. After these communications with Williams, the Journalist published a book and article that named Williams as a source and attributed specific statements to her. Some of these statements contained classified national defense information. In addition to her disclosures to the Journalist, Williams also made unauthorized disclosures of national defense information via her social media accounts that included details about the SMU structure, capabilities and internal workings.
“Courtney Williams swore an oath to safeguard our nation’s secrets as an employee supporting a Special Military Unit of the Army, but she allegedly betrayed that oath by sharing classified information with a media outlet and putting our nation, our warfighters, and our allies at risk,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “This indictment should serve as a stark warning to all current and former clearance holders thinking of violating their positions of trust. If you jeopardize our national security by disclosing classified information without authorization, the FBI will hold you accountable for your crimes.”
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April 14, 2026: The Department of Commerce’s Bureau of Industry & Security (“BIS”) reached a settlement with Coastal PVA Technology, Inc., under which the company agreed to pay $1,700,000 for eighteen violations of the EAR.
The violations involved the export of polyvinyl alcohol (“PVA”) brushes, between May 2021 and May 2024, to Semiconductor Manufacturing International (Beijing) Corporation (“SMIC Beijing”), and Semiconductor Manufacturing North China (Beijing) Corporation (“SMIC North”). At the time of exports via two third-party distributors, both SMIC Beijing and SMIC North were identified on the Entity List.
https://www.bis.gov/media/documents/coastal-pva-technology-final-order-4-13-2026.pdf
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April 15, 2026: The Justice Department announced the sentencings of two U.S. nationals, Kejia Wang, 42, and Zhenxing Wang, 39, for their roles in facilitating North Korean remote information technology (IT) workers posing as U.S. residents to obtain work at more than 100 U.S. companies. The multi-year scheme used the stolen identities of at least 80 U.S. persons and generated more than $5 million in illicit revenue for the government of the Democratic People’s Republic of Korea (DPRK).
From approximately 2021 until October 2024, the defendants and their co-conspirators compromised the identities of more than 80 U.S. persons to obtain remote jobs at more than 100 U.S. companies, including many Fortune 500 companies, and caused U.S. victim companies to incur legal fees, computer network remediation costs, and other damages of at least $3 million.
Kejia Wang, Zhenxing Wang and at least five facilitators in the United States received and hosted victim company laptops at their residences and enabled overseas IT workers to access the laptops remotely by, among other things, connecting the laptops to hardware devices designed to allow for remote access (referred to as keyboard-video-mouse or “KVM” switches).
Kejia Wang and Zhenxing Wang created shell companies with corresponding financial accounts, including Hopana Tech LLC, Tony WKJ LLC, and Independent Lab LLC, to make it appear as though the overseas IT workers were affiliated with legitimate U.S. businesses. In fact, these companies had no employees or operations and existed only to further the scheme and enable the defendants and their co-conspirators to receive proceeds from the scheme. These shell companies ultimately received more than $ 5 million dollars from victimized U.S. companies, much of which was subsequently transferred to overseas co-conspirators.
In addition to the defrauding of the companies, the IT workers employed under this scheme also gained access to sensitive employer data and source code, including International Traffic in Arms Regulations (ITAR) data from a California-based defense contractor that develops artificial intelligence-powered equipment and technologies. Specifically, between on or about January 19, 2024, and on or about April 2, 2024, an overseas co-conspirator remotely accessed without authorization the company’s laptop and computer files containing technical data and other information. The stolen data included information marked as being controlled under the ITAR.
Kejia Wang, of Edison, New Jersey, was sentenced to 108 months in prison for conspiracy to commit wire fraud, conspiracy to commit money laundering, and conspiracy to commit identity theft. Zhenxing Wang, of New Brunswick, New Jersey, was sentenced to 92 months for conspiracy to commit wire fraud and conspiracy to commit money laundering. In addition to the sentences of imprisonment, U.S. District Court Judge Nathaniel M. Gorton ordered the defendants to serve three years each of supervised release and to forfeit a total of $600,000 that was paid to them for facilitating the North Koreans. As of today, the United States has already received $400,000 of the ordered forfeiture amount. The court also ordered Kejia Wang to pay a judgment of $29,236.03 in restitution.
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April 17, 2026: The Department of State’s DDTC posted its consent agreement with General Electric Company (“GE”) alleging it violated the International Traffic in Arms Regulations (ITAR). The consent agreement imposed a $36 million fine and the appointment of a Special Compliance Officer for three years to oversee the implementation of corrective actions.
DDTC charged GE with 116 violations of the ITAR that occurred between April 17, 2018 and November 17, 2024. GE submitted 12 voluntary disclosures to DDTC between August 2019 and December 2024 reporting the violations.
The violations are related to USML Categories IV, I, VIII, XII, and XIX and involved:
- Unauthorized exports of USML Categories VIII(i) and XIX(g) technical data related to electrical power generation for the F-35 aircraft and the F414 military aircraft engine to the People’s Republic of China (PRC);
- Failure to manage DDTC authorizations properly;
- GE’s failed to properly validate the parties’ role in the transaction which resulted in the transfer of hardware or technical data to unauthorized end users and sublicensees.
- GE did not comply with provisos of a Technical Assistance Agreement and DSP-5 licenses.
- Unauthorized exports of USML Category XIX(f)(2) combustion liner designed for the F404-400 military aircraft engine to Sweden and USML Category VIII(h)(1) machined chassis specially designed for the F-35 aircraft to Israel; and
- Failure to report material changes to Respondent’s DDTC registration.
To correct deficiencies with its policies, procedures, and controls GE is to appoint, subject to the approval of DDTC, a SCO who will oversee implementation of the corrective actions. GE will, among other things:
- Ensure adequate resources are dedicated to ITAR compliance throughout the organization;
- Establish policies and procedures within the specified timelines;
- Implement a comprehensive automated export compliance system across the organization to improve oversight and control of exports, reexports, and transfers of technical data and hardware and the provision defense services;
- Perform a classification review to validate the export jurisdiction and classification of hardware, technical data, software, and defense services; and
- Perform at least one audit during the term of the consent agreement.
The Charging Letter, Agreement and the Order are attached.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=0bfa21fd97100f980083b3b0f053af9f
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=07faedbd97100f980083b3b0f053af14
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=cbfaedbd97100f980083b3b0f053af19
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April 23, 2026: The Department of Justice announced that Tianrui Liang, 21, of China, has been charged by complaint for conduct related to illegally documenting Air Force planes located at Offutt Air Force Base in Bellevue, Nebraska.
Offutt Air Force Base is a key base in the Air Force’s Strategic Command and is the home of Command-and-Control, reconnaissance and strategic support aircraft.
“Any individuals who unlawfully attempt to acquire sensitive information about military aircraft located in the District of Nebraska will be held maximumly accountable under federal law,” said U.S. Attorney Lesley Woods.
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April 23, 2026: The Department of Justice announced an indictment charging Gannon Ken Van Dyke, a U.S. Army soldier, with unlawful use of confidential government information for personal gain, theft of nonpublic government information, commodities fraud, wire fraud, and making an unlawful monetary transaction. The charges arise from an alleged scheme in which Van Dyke used sensitive classified information to make wagers on Polymarket, a prediction marketplace. As alleged in the indictment, Van Dyke participated in the planning and execution of the U.S. military operation to capture Nicolás Maduro, called “Operation Absolute Resolve,” and Van Dyke used his access to classified information about that operation to personally profit.
Van Dyke was involved in the planning and execution of Operation Absolute Resolve, a military operation to capture Maduro, and had access to sensitive, nonpublic, classified information about that operation.
On or about Dec. 26, 2025, Van Dyke created a Polymarket account, funded it, and began trading on Maduro- and Venezuela-related markets. In total, Van Dyke made approximately 13 bets from Dec. 27, 2025, through the evening of Jan. 26. Those bets all took the “YES” position on “U.S. Forces in Venezuela . . . by January 31, 2026”; “Maduro out by . . . January 31, 2026”; “Will the U.S. invade Venezuela by . . . January 31,”; or “Trump invokes War Powers against Venezuela by . . . January 31.” Van Dyke bet a total of approximately $33,034 on those outcomes while in possession of classified nonpublic information about Operation Absolute Resolve.
As a result of his access to classified information, Van Dyke won his wagers on those contracts. In total, Van Dyke allegedly profited approximately $409,881.
“Gannon Ken Van Dyke allegedly betrayed his fellow soldiers by utilizing classified information for his own financial gain,” said FBI Assistant Director in Charge James C. Barnacle Jr. “Van Dyke profited more than $400,000 by trading various outcomes related to Venezuela after learning of the operation because of his role as a U.S. Army soldier.
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for April 1 through April 30, 2026.
- Treasury Proposes Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance
https://ofac.treasury.gov/recent-actions/20260408_33
- Issuance of Amended Russia-related General License and Frequently Asked Questions; Publication of Spanish Translations of Venezuela-related General Licenses and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260408
- Venezuela-related Designation Removal; Issuance of Venezuela-related General Licenses and Frequently Asked Question; Publication of Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act (TSRA)
https://ofac.treasury.gov/recent-actions/20260414_33
- Counter Narcotics, Counter Terrorism Designations; Issuance of Related General License; Issuance of Amended Russia-related General Licenses and Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260414
- Iran-related Designations; Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260415
- Nicaragua-related Designations; Issuance of Nicaragua-related General License https://ofac.treasury.gov/recent-actions/20260416
- Counter Terrorism Designations; Sudan Designations
https://ofac.treasury.gov/recent-actions/20260417
- Counter Terrorism, Counter Narcotics, and Cyber-related Designations; Issuance of Cyber-related General License
https://ofac.treasury.gov/recent-actions/20260423
- Iran-related Designations; Counter Terrorism and Iran-related Designation Update; Issuance of Iran-related General License
https://ofac.treasury.gov/recent-actions/20260424
- Counter Terrorism Designation; Iran-related Designations; Issuance of Frequently Asked Question; Publication of Iran-related OFAC Alert
https://ofac.treasury.gov/recent-actions/20260428
- Issuance of Amended Russia-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260429
- Democratic Republic of the Congo-related Designation
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE APRIL 2026 Read More »
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE MARCH 2026
This newsletter is a listing of the latest changes in export control regulations through March 31, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
White House Unveils Cyber Strategy for America
March 6, 2026: The White House released “Cyber Strategy for America,” outlining the Administration’s priorities for ensuring that America remains unrivaled in cyberspace. It calls for unprecedented coordination across government and the private sector to invest in the best technologies and continue world-class innovation, and to make the most of America’s cyber capabilities for both offensive and defensive missions.
This strategy communicates the Administration’s cyber vision and approach to the American people, to Congress, to our partners in industry and allies across the globe—and also to adversaries. It explains the Administration’s priorities, summarized in six policy pillars, which will guide action and resourcing through the follow-on policy vehicles.
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Combating Cybercrime, Fraud, And Predatory Schemes Against American Citizens
March 6, 2026: 91 Fed. Reg. 12051: The President issued EO 14390 Combating Cybercrime, Fraud, And Predatory Schemes Against American Citizens, in which the policy of the U.S. is to protect Americans from, and harden our financial and digital systems against, these threats. The United States shall counter attacks on Americans with a commensurate response that includes law enforcement, diplomacy, and potential offensive actions. It is further the policy of the United States to provide support to victims of these crimes, expand public alerts, and prioritize protection for those most at risk to end the exploitation and victimization of Americans.
The EO directed the Secretary of State, the Secretary of the Treasury, the Secretary of War, the Attorney General, and the Secretary of Homeland Security, in consultation with the Office of the National Cyber Director, and in coordination with the Assistant to the President and Homeland Security Advisor (APHSA) to:
- Review the relevant operational, technical, diplomatic, and regulatory frameworks in place to determine how each can be improved to best combat Transnational Crime Organizations (TCOs) engaged in cyber-enabled crime and similar predatory schemes against Americans;
- Submit to the President, through the APHSA, an action plan that identifies the TCOs responsible for scam centers and cybercrime and proposes solutions to prevent, disrupt, investigate, and dismantle these TCOs;
- Submit a recommendation to the President, through the APHSA, regarding the establishment of a Victims Restoration Program designed to provide, to the greatest extent authorized by law and in consideration of the Department of Justice’s goal of serving all victims of crime, restoration or remission to victims of cyber-enabled fraud schemes from funds clawed back, forfeited, or seized from the TCOs that perpetrate such schemes; and
- Engage with foreign governments to demand enforcement actions against TCOs operating within their borders and greater cooperation with United States law enforcement.
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Adjusting Certain Delegations Under The Defense Production Act
March 13, 2026: 91 Fed. Reg. 14391: The President issued EO 14391 amending EO 13603 dated March 16, 2012(National Defense Resources Preparedness). Executive Order 13603 delegates certain authorities of the President under the Defense Production Act (50 U.S.C. 4501 et seq.), to specified executive department and agency (agency) heads. This order also clarifies section 2(a) of Executive Order 14156 of January 20, 2025 (Declaring a National Energy Emergency).
EO 14391 amended Section 203 of Executive Order 13603 by striking the phrase “Secretary of Commerce” and inserting, in lieu thereof, “Secretary of Commerce and the Secretary of Energy, each of whom may exercise such delegated authority independently of the other”.
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Fact Sheet: The President Strengthens U.S.-Japan Alliance for the Benefit of All Americans – The White House
March 19, 2026: The Administration released a fact sheet announcing new initiatives to strengthen the U.S.-Japan Alliance, enhance economic security, and bolster deterrence to advance a free and open Indo-Pacific.
Of note, the United States welcomed Japan’s commitment to rapidly strengthen its own defense capabilities, increase its defense budget, and continue partnering with U.S. forces in Japan and the region.
- The United States and Japan affirmed their commitment to deploying advanced capabilities in Japan to enable a strong denial defense posture. This year, the two sides will maintain close coordination, building on the successful 2025 deployment of the U.S. Typhon missile system to mainland Japan.
- Following the bilateral feasibility study for AIM-120 Advanced Medium-Range Air-to-Air Missile (AMRAAM) co-production, the two countries will scope Japan’s future role in increased AMRAAM production capacity.
- In support of missile defense cooperation, the two sides will rapidly increase by fourfold the production of Standard Missile 3 Block IIA missiles in Japan.
- The United States welcomed Japan’s commitment to develop a secure and sovereign cloud platform for government data to enhance bilateral information sharing, planning, and coordination.
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Department of State
Defense Trade Advisory Group; Notice of Membership
March 19, 2026: The U.S. Department of State’s Bureau of Political-Military Affairs (the Bureau) is accepting membership applications for the Defense Trade Advisory Group (DTAG). The Bureau is interested in applications from subject matter experts, including from the United States defense industry, relevant trade and labor associations, and academic and foundation personnel.
DTAG members’ responsibilities include:
- Making recommendations in accordance with the DTAG Charter and the FACA.
- Making policy and technical recommendations within the scope of the U.S. export controls as set forth in the AECA, the ITAR, and appropriate directives.
Please note that DTAG members may not be reimbursed for travel, per diem, and other expenses incurred in connection with their duties as DTAG members.
How to apply: Applications in response to this notice must contain the following information: (1) Name of applicant; (2) affirmation of U.S. citizenship; (3) organizational affiliation and title, as appropriate; (4) mailing address; (5) work telephone number; (6) email address; (7) resume; and (8) summary of qualifications for DTAG membership.
This information may be provided via two methods:
- Emailed to the following address: DTAG@State.Gov. In the subject field, please write, “ DTAG Membership Application. ”
- Send hardcopy to the following address: Paula Harrison, PM/DDTC, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political-Military Affairs, U.S. Department of State, Washington, DC 20522-0112. If sent via regular mail, we recommend you call Ms. Harrison (202-663-3310) to confirm she has received your package.
All applications must be postmarked no later than 15 days after the publication date of this notice.
Fiscal Year 2025 U.S. Arms Transfers and Defense Trade
March 16, 2026: The U.S. Department of State released the Fiscal Year 2025 U.S. Arms Transfers and Defense Trade
Total Sales:
In FY 2025 the number for total sales, both government to government Foreign Military Sales, and exports licensed via Direct Commercial Sales was $331.18 billion. This represents a 3.92 percent increase over the FY 2024 figure of $318.70 billion.
Foreign Military Sales:
In FY 2025 the total value of transferred defense articles and services and security cooperation activities conducted under the Foreign Military Sales system was $104.38 billion. This represents an 11.47 percent decrease, down from $117.85 billion in FY 2024. In FY 2025, the Department of State oversaw 16,098 FMS cases with an open case value of over $934 billion.
Direct Commercial Sales:
The total authorized value for privately contracted Direct Commercial Sales (DCS) authorizations for FY 2025 was $226.8 billion, which includes the value of hardware, services, and technical data authorized for exports, temporary imports, reexports, retransfers, and brokering. This represents a 12.9 percent increase, up from $200.8 billion in FY 2024.
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Directorate of Defense Trade Controls (DDTC)
Registration Application Enhancement Release
March 26, 2026: DDTC announced that beginning March 27, 2026, email notifications will be sent the day after a registration expires to the Senior Officer, Points of Contact, and Corporate Administrators associated with the registration. This notification is intended to provide timely prompt action for renewal, minimize the duration of any registration lapses, avoid lapse-related fees, and help organizations maintain ITAR compliance.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_homepage
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DDTC Name And Address Changes Posted To Website
March 1 through March 31, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Curtiss-Wright foreign subsidiary Ultra Nuclear Limited changed its name to Curtiss-Wright Wimborne Limited due to corporate restructuring.
- Mitsubishi Space Software Co., Ltd. changed its name to Mitsubishi Electric Software Corporation due to corporate restructuring.
- Muirhead Avionics UK changed its address from 3 The Square, Heathrow, UB2 5NH, South, United Kingdom to Muirhead Avionics UK, Quadrant House, 50 Heron Drive, Langley, Berkshire, SL3 8XP, United Kingdom.
- Neotek changed its name to RTsys Monitoring Solutions due to corporate rebranding.
- Schleifring North America, LLC’s subsidiary Electro-Miniatures Corp. changed its address from 68 W. Commercial Ave., Moonachie, NJ 07074 to 80 Hancock Street, Lodi, NJ 07644.
- TUSAS Motor Sanayii A.S. changed its address from Muttalip Mevkii Mrk Pk 610, Eskisehir 26003, Turkey to Esentepe Mahallesi Cevre Yolu Bulvari, No:356, Tepebasi, Eskisehir 26210, Turkey.
- GE Aviation Systems Australia Pty Ltd changed its address from 34 Boronia Road, Brisbane Airport 4008, Australia to 34 Boronia Road, Brisbane Airport, Brisbane 4008, Queensland, Australia.
- DSV Air & Sea, Inc. Entities Names and Locations due to corporate restructuring
- From: Avenida Presidente Riesco nùmero 5335 Oficinas 504 y 505, L 7561127 Santiago Chile
To: DSV Air & Sea S.A. Avenida Andres Bello 2687 Office 801 Building Del Pacifico, Las Condes, Santiago, Chile 755066 Santiago Chile
- From: Schenker d.o.o. Ulica Franje Lucica 32 10090 Zagreb Croatia
To: DSV Hrvatska d.o.o. Zelena aleja 55 10410 Velika Gorica Croatia; and
DSV Road Croatia d.o.o. Ulica Franje Lucica 32 10090 Zagreb Croatia
- From: AS Schenker Pärnu mnt 535 31136 Chihuahua 76404 Sakuv
To: DSV Air & Sea AS Pärnu mnt. 535 76401 Saku Vald Estonia; and
DSV Road AS Pärnu mnt 535 76404 Saku vald, Estonia Estonia
- From: Schenker A.E. Thesi Gropa Kyrillos 19300 Asproryrgos Greece
To: DSV Air & Sea Single Member S.A. 100 Alimou Ave. 164 52 Argyroupolis (Athens) Greece;
DSV Road Single Member S.A. 100, Alimou AV 164 52 Argyroupolis Athens Greece; and DSV Road Greece Thesi Gropa Kyrillosv 19300 Asproeyrgos Greece
- From: SIA Schenker Katlakalna iela 11c 1073 Riga Latvia
To: SIA DSV Latvia Krustpils street 31 1073 Riga Latvia
- From: Schenker Philippines Inc KM. 19, WSR, Sabrina Compound, Brgy. Marcelo Green Village 1700 Paranaque City Philippines
- To: DSV Air & Sea Inc. 6th Flr. West Tower 8912 Asean Avenue Bldg. Cor. N. Abueva 1700 Paranaque City Philippines;
DSV Contract Logistics, Inc. KM19 Sabrina Compound West Service Road Marcelo Green Village 1700 Paranaque City Philippines;
DSV Global Solutions Inc People’s Technology Complex, SEZ, Brgy Maduya, Carmona 4116 Cavite Philippines;
DSV Ecozone Logistics, Inc., Standard Factory Building 3, Laguna Technopark Brgy. Mamplasan 4024 Biñan Laguna Philippines; and
DSV Road KM19 West Service Rd., Sabrina Compound Marcelo Green 1700 Paranaque City Philippines
- From: Schenker Logistics AB Hangarvägen 1 438 70 Landvetter Sweden;
Schenker AB Österleden 201 261 51 Landskrona Sweden; and
Schenker Logistics AB Hangarvägen 1 438 70 Landvetter Sweden
To: DSV Air & Sea AB Österleden 201 261 51 Landskrona Sweden;
DSV Road AB Moelndalsvaegen 83 41285 Gothenburg Sweden; and
DSV Contract Logistics AB Österleden 201 261 51 Landskrona Sweden
- From: Schenker Schweiz AG Rautistr. 77 8048 Zuerich Switzerland
To: DSV Air & Sea AG St. Jakobs-Strasse 220 4052 Basel Switzerland; and
DSV Logistics S.A. Via Passeggiata 24 6828 Balerna, Switerland
- From: Schenker Saudi Arabia LLC Riyadh Avenue Mall, Avenue 2, 3rd Floor Hai Ul Murabba Riyad 51615 Riyadh Saudi Arabia
To: DSV Air and Sea for Logistics Services Company Blue Tower – 5th Floor (B-Wing), King Faisal Road – 13th street, P.O. Box 1499 31952 Al-Khobar Saudi Arabia; and
DSV Contract Logistics for Logistics Services Company Sinaeyat Slay – Istanbul Street 11464 Riyadh Saudi Arabia
- From: UAB “Schenker” Savanoriu ave. 5 03116 Vilnius Lithuania
To: DSV Lithuania UAB Stasylu 21 02244 Vilnius Lithuania
- From: Schenker (NZ) Limited 50 Richard Pearse Drive, Airport Oaks 2022 Auckland New Zealand
To: DSV Air & Sea Limited 19 Landing Drive, Auckland International Airport 2022 Auckland New Zealand - From: Schenker Logistics – L.L.C – S.P.C Hamdan bin Mohammed Street Abu Dhabi United Arab Emirates
To: DSV Contract Logistics PJSC PO Box 93971, Street No. 10, Sector M19, Mussafah Abu Dhabi United Arab Emirates
- From: Schenker of Canada Ltd. L4V 1W5 Mississauga, Ontario 5935 Airport Road, 10th floor Canada
To: DSV Air & Sea Inc. 2200 Yokon Court Ontario L9E 1N5 Milton Canada;
DSV Road Inc 2200 Yokon Court Ontario L9E 1N5 Milton Canada; and
DSV Contract Logistics Inc. 2200 Yokon Court Ontario L9E 1N5 Milton Canada
- From: Schenker France SAS Z.I. Nord 85600 Montaigu France
To: DSV Air & Sea SAS 9-23 Chemin des Petits Marais 92230 Gennevilliers France;
DSV Road SAS 19-23 Chemin des Petits Marais 92230 Gennevilliers Cedex France; and
DSV Contract Logistics SAS 33, Rue de Reckem 59960 Neuville en Ferrain France
- From: Schenker Vietnam Co. Ltd 14th Floors-Tower A, 285 Cach Mang Thang 8 Hoa Hung Ward Ho Chi Minh City Viet Nam
To: DSV Air & Sea Company Limited 3B FLOOR REPUBLIC PLAZA BUILDING, 18E CONG HOA ST., WARD 4, TAN BINH DISTRICT Ho Chi Minh City Vietnam
- From: Schenker Italiana S.p.A. (à DSV Road Spa) Via Fratelli Bandiera 29 20068 Peschiera Borromeo (MI) Italy
To: DSV SpA (à DSV Air&Sea Spa) Via Dante Alighieri 134 20096 Pioltello Italy; and
DSV Solutions S.R.L (à DSV Contract Logistics Srl.) Via Dante Alighieri 134, Frazione Limito 20096 Pioltello Italy
- Luerssen Australia Pty Ltd changed its ownership and name as follows:
- Previous Owner Name and Address:
NVL B.V. Co. ZKG Zum Alten Speicher 11 28759 Bremen, Germany
New Owner Name and Address:
Civmec Limited (CVL) 16 Nautical Drive, Henderson, WA 6166 Australia
- Entity Named on Existing Agreement:
Luerssen Australia Pty Ltd. (Luerssen) 16 Nautical Drive, Henderson, WA 6166 Australia
New Entity:
Civmec Defence Industries (CDI) 16 Nautical Drive, Henderson, WA 6166 Australia
- L3Harris Interstate Electronics Corporation changed its address from 602 E. Vermont Avenue, Anaheim, California 92805 to 22745 Savi Ranch Parkway, Yorba Linda, California 92887
- General Electric International Inc. changed its name to Arcam AB due to corporate restructuring.
- LIG Nex1, Ltd. changed its name to LIG Defense & Aerospace Co., Ltd. due to corporate rebranding.
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DDTC Frequently Asked Questions (FAQs)
Q: How can a user become a Corporate Administrator (CA) in DECCS?
A: (Updated 3/2/2026) A user can become a Corporate Administrator (CA) in DECCS through the following methods:
- Designation by an Existing CA
An existing Corporate Administrator can designate any user as a CA via the DECCS User Management (UM) application.
- Senior Officer (SO) Request
If you are a Senior Officer, you can use last year’s signed registration notification letter from DDTC in place of a CA Request letter, provided the letter includes:
- Company name
- Registration code
- Your name as the Senior Officer
- Submission of a CA Request Letter
Send a CA Request letter on company letterhead in PDF format with the following details:
- Date
- Company name and mailing address
- DDTC registration code
- Brief description of the request (e.g., Request for John Smith to be designated as a CA)
- Title and contact information of the requested CA (name, phone number, and email used for DECCS enrollment)
- Senior Officer (SO)/Empowered Official (EO) signature (handwritten or cryptographic-based; font-based signatures are not allowed) in addition to their title and contact information.
Important Notes
- Ensure your company has no new registrations in progress before submitting the CA Request letter. Any renewal registration will fail if new registrations are active.
- It is recommended to have multiple Corporate Administrators to avoid disruptions due to absences or departures.
Submission Methods
Send the CA Request letter to DDTC Help Desk using one of the following methods:
- Update an Existing Support Case: Log into DECCS, go to My Support Cases, click Needs Attention, locate the case, and upload the CA Request letter.
- Create a New Support Case: Log into DECCS, go to My Support Cases, and click Create a New Support Case. Refer to How do I submit a Support Case request?
Processing Time
Once the request is received, allow 1–2 business days for completion.
Q: How do I add a new Corporate Administrator (CA) in DECCS?
A: To add a new Corporate Administrator (CA), you must already be a CA yourself. Follow these steps to designate another user as a CA:
- Log in to DECCS and click the Applications menu in the top navigation bar.
- Select the User Management option.
- In the Company Users section, find the user you want to make a CA.
- Check the CA checkbox next to the user’s email address.
- Once the change is applied, a green banner will appear at the top of the screen with the message: “User Updated Successfully.”
The user will now have Corporate Administrator privileges and can manage user accounts and access within your organization.
Q: How do I switch my DECCS profile to a new email address?
A: To switch your DECCS profile to a new email address, you’ll need to create a new DECCS account using your new email and have your Corporate Administrator (CA) connect it to your company’s profile.
You may need to do this if you’ve changed companies, updated your organization’s email domain, or no longer have access to your old email account.
Steps:
- Create your new DECCS account – Go to https://deccs.pmddtc.state.gov/deccs and click Enroll.
-
- Register using your new email address and complete the Okta verification process.
- Request company access- If you’re a Corporate Administrator (CA), log into DECCS with your old account and invite your new email under Applications → User Management → Add User.
-
- If you’re not a CA, ask your CA to send this invitation.
- Accept the invitation – Log into DECCS with your new account and accept the company invitation under User Management.
- Update roles and permissions (CA required) – Your CA must assign your Registration and Licensing roles to the new account and mark it as a Corporate Administrator, if applicable.
- Remove your old account – Once the new account is active, your CA should remove your old email from the company user list.
- Clean up – Delete the old account from your Okta Verify app.
- Submit a Support Case (from your old account email) requesting deactivation of the old DECCS account. Include the old email address in your message.
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REMINDER: It’s Time For Annual Sales Report Filings To Be Made With DDTC For Manufacturing License Agreements And Warehousing Distribution Agreements For Sales And Transfers That Occurred In 2025
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
Israel
Sweden
United Arab Emirates
Jordan
Kuwait
United Kingdom
Republic of Korea
Japan
Belgium
https://www.state.gov/israel-munitions-and-munitions-support/
https://www.state.gov/united-arab-emirates-advanced-medium-range-air-to-air-missiles-amraams/
https://www.state.gov/government-of-jordan-aircraft-repair-return-and-spares/
https://www.state.gov/japan-hyper-velocity-gliding-projectile-hvgp-program-support/
https://www.state.gov/belgium-communications-equipment/
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Department of Commerce – Bureau of Industry and Security (BIS)
Exports of U.S.-Origin Gas and Petroleum Products to Cuba
March 4, 2026: BIS updated its guidance regarding the availability of License Exception SCP for exports and reexports of U.S.-origin gas and other petroleum products to eligible Cuban private sector entities and to individual Cuban consumers. Certain transactions that meet SCP terms may be authorized without a license, and applications that otherwise qualify will be returned without action with instruction to use the exception. Exporters are responsible for ensuring that all SCP conditions are met and should carefully review § 740.21 before proceeding.
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Suspension Related to Cuban-Owned Banks
March 4, 2026: BIS suspended the availability of License Exception Support for the Cuban People (SCP) under § 740.21(b)(1) for any export, reexport, or transfer involving the deposit of foreign funds into a Cuban‑owned bank. BIS determined that such transactions present an unacceptable risk of primarily benefiting the Cuban government and its military or intelligence services. This suspension does not apply to transactions that avoid Cuban banks, such as those routed through third‑country financial institutions, nor to shipments already en route by March 4, 2026, if completed by April 3, 2026. Exporters remain responsible for ensuring full compliance with § 740.21 and all SCP conditions before proceeding.
BIS updated its Cuba Export Controls Country Guidance by adding Suspension Related to Cuban-Owned Banks.
BIS determination to suspend the availability of License Exception SCP under § 740.21(b)(1) for any export, reexport, or transfer (in-country) involving a Cuban owned bank
- There are longstanding and documented issues of diversion and fees associated with Cuban banks. The Cuban banks form the basis of the regime’s financial infrastructure, and many are designated on the Cuba Restricted List due to being under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel. It is well established that it is not the policy of the United States to permit transactions that significantly benefit the Cuban government or its designated military institutions.
- Accordingly, transactions involving the deposit of foreign funds into Cuban government banks, including those on the Cuba Restricted List or associated with the military and intelligence services, may serve to primarily generate revenue for or contribute to the operation of the Cuban state.
- Taking these considerations above into account and the need to protect U.S. national security and foreign policy interests, BIS has determined that there is an unacceptable risk that transactions involving Cuban banks may primarily benefit the Cuban government, contrary to the purpose of License Exception SCP of supporting independent economic activity in Cuba.
- Pursuant to § 740.2(b) of the EAR, which specifies that “all License Exceptions are subject to revision, suspension, or revocation, in whole or in part, without notice to protect U.S. national security or foreign policy interests,” BIS is informing all exporters, reexporters, and transferors that License Exception Support for the Cuban People (SCP), § 740.21(b)(1), is suspended as of March 4, 2026, for any export, reexport, or transfer (in-country) involving the deposit of foreign funds into a Cuban owned bank.
- This BIS suspension does not apply to exports, reexports, or transfers (in-country) that do not involve Cuban banks, e.g., involving third country banks or other financial payment systems that do not involve the deposit of foreign funds into Cuban banks. This BIS suspension also does not apply to any export or reexport that was en route aboard a carrier to a port of export or reexport on March 4, 2026, pursuant to actual orders for export or reexport to Cuba, provided that the export or reexport is completed no later than April 3, 2026.
Updated Guidance Regarding Available EAR License Exceptions for Exports of Gas and Petroleum Products to Cuban Private Sector Entities and Activities
- The Bureau of Industry and Security (BIS) has been receiving questions from potential exporters on the EAR requirements and potential EAR authorizations that may be available to authorize exports of gas and petroleum products and reexports of U.S.-origin gas and petroleum products for private sector use, including for addressing humanitarian needs in Cuba.
- In general, a license is required to export and reexport gas and other petroleum products that are subject to the EAR to Cuba pursuant to § 746.2(a). However, as with any export or reexport that is subject to a license requirement, the exporter or reexporter should first evaluate whether a license exception is available to authorize the export or reexport.
- In particular, exporters and reexporters of gas and petroleum products subject to the EAR to the Cuban private sector should review the general restrictions under § 740.2 and § 740.21. As explained below, gas and other petroleum products exported and reexported to Cuban private sector entities or individuals for personal use (or their fa may be authorized under License Exception SCP.
- Exporters and reexporters are advised that if a license application is submitted to BIS that otherwise meets the terms and conditions of License Exception SCP, those applications will be returned without action (RWA’d) by BIS with a direction to the applicant to export or reexport the items pursuant to License Exception SCP.
- BIS provides the following FAQ to further assist public understanding:
Q.1: Would License Exception Support for the Cuban People (SCP) (§ 740.21 of the EAR) allow an exporter or reexporter to export or reexport gas and other petroleum products to Cuban private sector entities for private sector use, or directly to individual Cubans for their personal or family use?
A.1: Yes, provided that all the applicable terms and conditions of License Exception SCP are met. Specifically, there are two authorizing paragraphs under License Exception SCP under paragraph (b) (Improving living conditions and supporting independent economic activity), which may be available to authorize these types of exports and reexports of gas and other petroleum products to Cuba. License Exception SCP provides a general authorization for exports under certain applicable conditions, as explained below, and does not contain any specific limitations on applicability based on quantity or value of the items, or exporter or reexporter.
- 740.21(b)(1). Exports to private sector for private sector use. If the gas and other petroleum products are being exported (or reexported) for use by the Cuban private sector for private sector use, then paragraph (b)(1) of License Exception SCP, which authorizes items for use by the Cuban private sector for private sector economic activities, may be available to authorize these types of exports and reexports. To qualify, exports must be both (1) for use by the Cuban private sector, and (2) for private sector economic activities, including those addressing humanitarian needs in Cuba. Per § 740.21(b)(1)(i) and (ii), License Exception SCP does not apply to any transactions, whether to Cuban private sector entities or otherwise, which primarily generate revenue for the state; or contribute to the operation of the state, including through the construction or renovation of state-owned buildings.
- 740.21(b)(2). Exports sold directly to individuals in Cuba for their personal use.
If the gas and other petroleum products are sold directly to individuals in Cuba for their personal use, then paragraph (b)(2) of SCP, which authorizes items sold directly to individuals in Cuba for their personal use (or their immediate family’s personal use), may be available to authorize exports and reexports of such products.
Paragraph (b)(2) does not require the products to be exported or reexported directly to the individuals; however, the products must ultimately be destined for these eligible end users (and/or their families) for their personal use.
This authorization applies only if the gas or other petroleum products are sold directly to individual Cubans for their personal use or the use of their immediate family. It does not apply if any of the products are sold or transferred to proscribed persons or entities in Cuba, including employees of the Ministry of Defense or Ministry of the Interior, senior officials of certain Cuban government organizations, labor unions, and other Cuban government affiliated organizations, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 CFR 515.209.
Note: Exporters and reexporters are responsible for ensuring that all of the applicable terms and conditions of License Exception SCP are met. Please review EAR § 740.21 — License Exception Support for Cuban People (SCP) — carefully to ensure that your transaction meets all the criteria for use of the license exception. Exporters who are unable to determine if they can satisfy all terms and conditions of License Exception SCP should submit an application for an individual validated license.
https://www.bis.gov/media/documents/030426-scp-gas-petroleum-bank-faq.pdf
https://www.bis.gov/licensing/country-guidance/cuba-export-controls
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Department of Commerce – International Trade Administration
Department of Commerce Announces New American AI Exports Program Phase
March 16, 2026: The U.S. Department of Commerce announced further implementation of the American AI Exports Program with a Call for Proposals from U.S. industry-led consortia to export full-stack AI technology packages. Under President Donald J. Trump’s AI Action Plan and export directives, the Department of Commerce is implementing a full-stack AI export package promotion program to advance America’s AI leadership globally.
Beginning April 1, 2026, and for 90 days, industry-led consortia may submit proposals for full-stack AI export packages, including AI optimized computer hardware, data center storage, models, cybersecurity measures, and applications for various sectors.
The call for proposals includes two types of industry-led consortia: pre-set consortium and on-demand consortium. Pre-set consortia demonstrate capability across all layers of the AI technology stack and maintain global offerings ready for deployment on an ongoing basis. These will become the U.S. Government’s offerings to allies and partners around the world. On-demand consortia are formed by industry in response to a specific opportunity identified by the Program and need only cover the stack layers required for the specific deal. These on-demand consortia are formed as “custom-made” options for specific opportunities.
Both pre-set and on-demand consortia are designated through a single selection process: the Secretary of Commerce, in consultation with the Secretary of State, the Secretary of War, the Secretary of Energy, and the Director of the Office of Science and Technology Policy, selects proposals for inclusion in the Program. Once approved, full-stack AI technology can be available to trusted foreign buyers of U.S. technology.
Under the Program, approved consortia may also receive support from across the U.S. Government, including priority for export control license reviews, prioritized access to U.S federal credit programs, government-to-government engagement via direct advocacy, and dedicated interagency coordination.
Full program information and proposal processes will be published in a forthcoming Federal Register notice.
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Federal Communications Commission
On March 23, 2026, the Federal Communications Commission updated its Covered List to include all consumer-grade routers produced in foreign countries. Routers are the boxes in every home that connect computers, phones, and smart devices to the internet. This followed a determination by a White House-convened Executive Branch interagency body with appropriate national security expertise that such routers “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.
See our articles on this topic on FD Associates’ LinkedIn page.
https://docs.fcc.gov/public/attachments/DOC-420034A1.pdf
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
February 25, 2026: Gerald Eddie Brown, Jr., 65, a former U.S. Air Force officer and pilot, was arrested in Jeffersonville, Indiana, and charged by criminal complaint for providing, and conspiring to provide, unauthorized defense services to Chinese military pilots in violation of the Arms Export Control Act.
Since August 2023, Brown willfully conspired with foreign nationals to provide combat aircraft training to pilots in the Chinese Air Force, known as the People’s Liberation Army Air Force (PLAAF). This training was a defense service under the International Traffic in Arms Regulations (ITAR) and Brown lacked the required license from the State Department’s Directorate of Defense Trade Controls to provide that training to foreign persons or foreign military units.
Brown served for more than 24 years in the U.S. Air Force and retired in 1996 with the rank of Major. During his military career, Brown commanded sensitive units with responsibility for nuclear weapons delivery systems, led combat missions, and served as a fighter pilot instructor and simulator instructor on a variety of fighter and attack aircraft, including the F-4 “Phantom II,” F-15 “Eagle,” F-16 “Fighting Falcon,” and the A-10 “Thunderbolt II” (Warthog). Brown then served as a commercial cargo pilot and, most recently, as a contract simulator instructor for two different U.S. defense contractors training U.S. military pilots on flying the A-10 and the F-35 Lightning II Joint Strike Fighter.
In August 2023, Brown began arranging the terms of his contract to train Chinese military pilots, using a co-conspirator to negotiate with Stephen Su Bin, a Chinese national who in 2016 pleaded guilty in the U.S. District Court for the Central District of California to conspiring to hack into the computer networks of major U.S. defense contractors and to steal sensitive military and export-controlled data for the PRC. Su Bin was sentenced to nearly four years in prison. Su Bin and his company PRC Lode Technology Company also were added to the U.S. Department of Commerce’s Entity List in 2014.
Throughout these communications, Brown consistently stated his intent to train PRC military pilots in combat aircraft operations. In the resumé he prepared for his application, Brown wrote his “objective” as “Instructor Fighter Pilot.” A co-conspirator told Brown that he hoped Brown would be assigned to “my base, but otherwise you’ll go where is the local equivalent as the [U.S. Air Force] Weapon School.” Later, Brown stated to a co-conspirator that, upon his arrival in China, “Now…. I have the chance to fly and instruct fighter pilots again!”
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March 17, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that TradeStation Securities, Inc. (“TradeStation”) has agreed to pay $1,110,661 to settle its potential civil liability for 481 apparent violations of OFAC sanctions programs arising from TradeStation’s provision of brokerage and investment services to persons in Iran, Syria, and Crimea, between June 2021 and June 2022. The settlement amount reflects OFAC’s determination that TradeStation’s conduct was non-egregious and was voluntarily self-disclosed.
TradeStation implemented compliance systems to comply with U.S. sanctions. The compliance systems included:
- Background checks of prospective customers that include screening against OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”) and rescreenings of its existing customers against the SDN List on a daily basis. Each customer’s primary residence is screened to ensure they do not reside in a sanctioned jurisdiction.
- IP Geo-blocking technology to verify the location of its users while they utilized TradeStation’s web-based and mobile platforms to prevent access to TradeStation’s platforms from sanctioned jurisdictions. A key element of this system was a firewall designed to deny users with IP addresses associated with sanctioned jurisdictions from accessing TradeStation’s systems (the “first-tier geo-blocking”). TradeStation ran a separate third-party IP address verification tool that acted as a second layer of defense by authenticating a user’s IP address upon login to TradeStation’s web-based and mobile platforms and denied access based on location (the “second-tier geo-blocking”).
- Subscription to a third-party service that alerted TradeStation’s sanctions compliance personnel to access attempts that had been prevented by the geo-blocking controls. These notifications, which were delivered daily, documented efforts by TradeStation clients to access its platforms in jurisdictions subject to OFAC sanctions and other certain jurisdictions.
The violations are the result of:
- Failures In Tradestation’s IP Geo-Blocking Measures
- TradeStation designed and implemented proprietary software to improve the functionality and the overall user experience of TradeStation’s mobile platform. This new software, however, inadvertently rendered TradeStation’s second-tier geo-blocking ineffective for users of its mobile platform. Instead of identifying and screening the user’s IP address at the time of an attempted login to prevent users from sanctioned jurisdictions from trading, the second-tier geo-blocking protocol detected the IP address of the U.S.-located server from which TradeStation’s new mobile platform software ran. This prevented the second-tier geo-blocking controls from functioning as designed, rendering them incapable of identifying users in Iran, Syria, and Crimea.
- Additionally, one of TradeStation’s employees inadvertently failed to reenable the first-tier geo-blocking control after disabling it to install a software update from TradeStation’s cloud services provider. This left TradeStation’s first-tier geo-blocking controls effectively disabled, and they remained so for nearly 12 months. During this period, TradeStation was not restricting access to its mobile platform by users with IP addresses associated with sanctioned jurisdictions (although sanctioned users attempting to access the web-based platform would have been blocked by the second-tier geo-blocking controls). Consequently, users located in Iran, Syria, and Crimea were able to access TradeStation’s mobile platform and execute 481 trades during this time
- Failures To Test Or Validate Sanction Compliance Systems
- TradeStation developed an automated testing tool for its on-premises servers that would simulate access attempts by users with IP addresses associated with sanctioned jurisdictions. However, TradeStation later discovered that its third-party internet service and cloud providers were blocking these test access attempts before they could reach TradeStation’s systems. TradeStation discontinued the use of this tool without replacing it, and, as a result, TradeStation had no effective testing mechanism—neither related to its on-premises servers nor its mobile platform—in place to ensure that its IP geo-blocking controls were functioning as intended at the time the 481 apparent violations occurred.
- TradeStation maintained a third-party service that alerted sanctions compliance personnel of access attempts from sanctioned jurisdictions. On September 21, 2021, a TradeStation-affiliated employee received an email from the third-party provider of its daily notifications that TradeStation’s subscription would be expiring. This employee failed to renew the subscription and did not notify others in TradeStation’s sanctions compliance department about the expiration of the daily notifications. For a period of over eight months, TradeStation’s sanctions compliance personnel failed to address the absence of its once-daily OFAC alerts and did not consider or act on what the lack of notifications might have signaled about TradeStation’s sanctions compliance program.
Key Take Aways:
OFAC made the point to highlight:
- The importance of regular testing and auditing to ensure sanction compliance controls are effectively mitigating risk and preventing violations. The most well-designed sanctions compliance program can be rendered wholly ineffectual by human and technical errors. Comprehensive, independent, and objective testing and auditing can help catch problems early and provide opportunities for remediation, thereby limiting risk of violating sanctions.
- Regular testing and auditing also provide opportunities for evaluating sources of sanctions risk and ensuring that appropriate controls are in place to address them. Controls should be well designed to address particular sanctions risks, including those presented by particular technology offerings. These controls may include appropriately calibrated screening protocols, geo-blocking controls, and Virtual Private Network detection software. They may also include controls to validate proper system operation and execution following any outage, including due to planned maintenance or upgrade.
- Companies should not treat testing and auditing as box-checking exercise. Sanctions risks are dynamic and may fluctuate as prohibitions change or as businesses evolve. While technological solutions are often a critical part of an effective sanctions compliance program, firms should ensure they are not overly relying on a patchwork of software or taking a “set it and forget it” approach to compliance.
https://ofac.treasury.gov/recent-actions/20260317
https://ofac.treasury.gov/media/935351/download?inline
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March 19, 2026: The Department of Justice charged Yih-Shyan “Wally” Liaw, Ruei-Tsang “Steven” Chang, and Ting-Wei “Willy” Sun, for allegedly conspiring to divert high-performance computer servers assembled in the United States and integrating sophisticated U.S. artificial intelligence technology manufactured by Nvidia Corporation to China, in violation of U.S. export controls laws. Liaw, a U.S. citizen, and Sun, a citizen of Taiwan, were arrested and will be presented in the Northern District of California. Chang, a citizen of Taiwan, remains a fugitive.
Liaw is a co-founder, board member, and Senior Vice President of Business Development of Super Micro Computer, a publicly traded U.S.-based manufacturer that designs and builds high-performance computer servers for artificial intelligence and cloud computing applications, including servers that integrate Nvidia artificial intelligence graphics processing units (GPUs). Chang is a general manager in the U.S. Manufacturer’s Taiwan office. Sun is a third-party broker and “fixer” who has worked with Liaw, Chang, and others to divert U.S.-export controlled technology to China. Together, the defendants and others conspired to systematically divert the U.S. Manufacturer’s servers with certain GPUs to China without a license to do so from the U.S. Department of Commerce.
The scheme operated as follows. Liaw and Chang, who worked closely with third-party brokers with customers based in China, directed certain executives of a company based in Southeast Asia (“Company-1”) to place purchase orders with the U.S. Manufacturer for servers with certain GPUs, purportedly for Company-1. Those servers were often assembled in the United States and shipped to the U.S. Manufacturer’s facilities in Taiwan, then delivered to Company-1 elsewhere in Southeast Asia. Company-1, in consultation with the defendants, then used a shipping and logistics company to repackage the U.S. Manufacturer’s servers and place them in unmarked boxes to conceal their content prior to shipping them to their final destinations in China. To ensure that these server allocations were approved internally at the U.S. Manufacturer, the defendants and executives at Company-1 prepared false documents and records, and transmitted false communications, purporting to show that Company-1 was the end user of the servers.
The defendants and their co-conspirators took extensive measures to conceal their scheme. As just one example, to deceive the U.S. Manufacturer’s compliance team, responsible for ensuring adherence to U.S. export control laws, the defendants staged thousands of “dummy” servers—non-working, physical replicas of the U.S. Manufacturer’s servers—for inspection at the locations where Company-1 was purportedly storing the servers it had purchased from the U.S. Manufacturer. However, the actual servers purchased by Company-1 from the U.S. Manufacturer had already been unlawfully shipped to China.
See our article on this topic at: The Compliance Illusion – FD Associates, Inc.
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March 20, 2026: The Department of Justice announced the former Chief Executive Officer of Nodus International Bank (Nodus Bank), a Puerto Rican international bank, plead guilty on March 19, 2026 for leading a scheme to fraudulently obtain at least $24.9 million from Nodus Bank and conspiring to evade U.S. sanctions against Venezuela.
“This defendant used his position as CEO to siphon more than $24 million, hide conflicts of interest, and help drive the bank’s collapse,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “The scheme also involved efforts to evade U.S. sanctions tied to Venezuela’s state-owned oil company, PDVSA. As a career prosecutor and former state trial judge, I’ve learned that following the money reveals the truth. Here, it exposed both fraud and sanctions violations. We will hold accountable anyone who abuses our financial system for personal gain.”
Tomás Niembro Concha, 64, of Miami, Florida, conspired with others to siphon money from Nodus Bank, ultimately leading to the bank’s failure in 2023. Niembro and his co-conspirators concealed from other Nodus Bank board members and executives and the bank’s regulator that certain investments and loans were for the benefit of Niembro and Board Chairman Juan Ramirez, in violation of Puerto Rican law. From 2017 to 2023, Niembro, Ramirez and others caused Nodus Bank to invest $11 million in a Miami-based lender so those funds could be loaned to Niembro and Ramirez for their own benefit. Niembro and his co-conspirators knew that these transactions were illegal and concealed their conduct through the sham investments.
Between January 2018 and September 2021, Niembro and Ramirez also fraudulently induced Nodus Bank’s board and comptroller to agree to buy at least 47 promissory notes totaling approximately $25.3 million from Nodus Finance, a Miami-based company that Niembro and Ramirez jointly owned, so they could use the proceeds of the transactions for themselves.
In early March 2023, Nodus’s regulator, the Office of the Commissioner of Financial Institutions of Puerto Rico (OCIF), notified the bank it would be placed into liquidation. Niembro and Ramirez fraudulently caused Nodus Bank to accept a loan portfolio from Nodus Finance to pay down the debt from the 47 promissory notes.
Moreover, between 2021 and 2023, Niembro conspired with others to conduct prohibited financial transactions with an individual designated as a Specially Designated National (SDN) by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for providing material support to Venezuela’s state-owned oil company, Petróleos de Venezuela, S.A. (PDVSA). To satisfy an outstanding loan of approximately $2.5 million that the SDN’s company had with Nodus Bank prior to the imposition of sanctions, Niembro and the SDN devised a scheme to cause Nodus Bank to foreclose on the SDN’s home in Southampton, NY — for which they obtained OFAC authorization — but separately reached a “private” agreement to induce Nodus Bank to sell the property back to the SDN for $4 million through a front company — a transaction that was strictly prohibited by U.S. sanctions and not otherwise licensed by OFAC.
Niembro pleaded guilty to a two-count Information charging conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (IEEPA). Each charge carries a maximum penalty of 20 years in prison. Niembro’s sentencing has been scheduled for June 8. As part of his plea agreement, Niembro agreed to forfeit at least $16.9 million, which represents the value of the proceeds he derived from the wire fraud conspiracy. A federal judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.
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March 25, 2026: The Department of Justice charged Stanley Yi Zheng, Matthew Kelly, and Tommy Shad English with conspiring to commit smuggling and export control violations. The three defendants are alleged to have sought millions of dollars’ worth of export-controlled computer chips from a California-based computer hardware company for illegal shipment to China through Thailand.
“Zheng, Kelly, and English allegedly conspired to sell millions of dollars’ worth of American-made AI computer chips to buyers in China, in clear violation of U.S. export controls,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “As our foreign adversaries escalate their efforts to dominate the field of artificial intelligence, we are seeing them employ increasingly brazen schemes to illegally acquire valuable U.S. technology. Enforcing export controls is critical to our work safeguarding America’s economic and national security, and the FBI will continue working with our partners to protect our nation’s innovation and hold accountable those seeking to profit by supplying hostile nation states.”
According to the criminal complaints and other information presented in court: In or about May 2023, Zheng, Kelly, and English began conspiring together to obtain computer servers with export-controlled computer chips from a California-based computer hardware company (Company-1) and ship them to Thailand with an ultimate destination of China, in violation of U.S. law. In doing so, the three defendants used the names of Thailand-based companies as the purported purchasers of the computer servers when in fact the co-conspirators intended for the U.S.-origin AI chips to be diverted to China.
In Oct. 2023, English, purporting to act on behalf of a Thailand-based company, ordered 750 computer servers for approximately $170 million from Company-1. Of the 750 computer servers, 600 contained a computer chip that was controlled on the U.S. Commerce Control List and required a license for export to China. In placing that order, English signed an “Advanced Computing Certification,” certifying that the computer servers were not destined for China or any other country subject to heightened export requirements.
In Jan. 2024, English transferred over $20 million to Company-1 as partial payment for the Oct. 2023 order. In Jan. 2024, when discussing via email an upcoming compliance review for the Oct. 2023 order, English asked Company-1 to add Zheng and Kelly to the email thread, which prompted a response from Company-1 noting, among other things, that Zheng’s company was based in China and that it was “odd” that no one from the Thailand-based company was in the list of carbon copy recipients. Company-1 also commented that “China is an embargoed country restricted by the US government. US companies are restricted from selling to businesses or end users headquartered in China.”
In early Feb. 2024, additional review of the Oct. 2023 order was conducted by the California-based manufacturer of the computer chips that would be inside 600 of the servers English had ordered (Company-2). Company-2’s efforts to verify the end user of the computer chips in Thailand were unsuccessful. Ultimately, the Oct. 2023 purchase was not completed.
While the Oct. 2023 deal lost momentum, in April 2024, English, purporting to act on behalf of a second Thailand-based company, sought to order from Company-1 another 500 computer servers that contained an export-controlled computer chip. In doing so, English signed an End User Certification stating that the Thailand-based company was the end user for the purchase. This deal, like the Oct. 2023 deal, ultimately was unsuccessful.
Text messages obtained through the investigation illustrated aspects of the conspiracy and revealed that Zheng, English, and Kelly discussed, among other things, “fake” corporate niceties to help complete the computer chip purchases, the value of the computer chips in China, and recruitment of others to participate in the scheme.
This case is being investigated by the Department of Commerce’s Bureau of Industry & Security, the Defense Criminal Investigative Service, Homeland Security Investigations, and the Federal Bureau of Investigation as the result of a tip that BIS received through an email account listed on the BIS website.
Assistant U.S. Attorney Samir Kaushal of the United States Attorney’s Office for the Northern District of Georgia and Trial Attorney Brett Ruff of the National Security Division’s Counterintelligence and Export Control Section are prosecuting the case.
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March 30, 2026: Manfred Gruber, an Italian national, plead guilty to conspiracy to commit export control violations. Gruber illegally exported ammunition worth over $540,000 from the United States to Kyrgyzstan, via companies that the defendant and his co-conspirator controlled in Italy. After reaching Kyrgyzstan, most of this ammunition was subsequently reexported to Russia.
In January 2026, Sergei Zharnovnikov, a Kyrgyzstan-based co-conspirator of the defendant, was sentenced to 39 months’ imprisonment after pleading guilty to violating the Export Control Reform Act.
“Manfred Gruber put many lives at risk by illegally supplying Russia with hundreds of thousands of dollars’ worth of American-made, military-grade ammunition to advance its war in Ukraine,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division.
“The defendant used multiple companies to hide his scheme to send military‑grade ammunition to Kyrgyzstan, before it was reexported to Russia to support its war effort,” stated United States Attorney Joseph Nocella for the Eastern District of New York. “I commend our partners at the FBI and the Department of Commerce for uncovering this deadly scheme and swiftly bringing Gruber to justice.”
Sanctions
Department of Commerce, Bureau of Industry & Security
March 31, 2026: 91 Fed. Reg. 15948: The Department of Commerce, Bureau of Industry & Security issued an order renewing temporary denial of export privileges of Aviastar – TU (”Aviastar”).
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for March 1 through March 31, 2026.
- OFAC issued 10 new/amended General Licenses and 13 new Frequently Asked Questions related to Venezuela Sanctions.
- OFAC issued 5 new General Licenses and 2 new Frequently Asked Questions related to Russia Sanctions.
- OFAC issued 1 new General License related to Belarus Sanctions.
- OFAC issued 1 new General License related to Iran Sanctions.
- OFAC issued 1 new General License related to the sanctioning of the Rwanda Defence Force.
- OFAC issued Guidance on Sham Transactions and Sanctions Evasion.
- OFAC added to the Specially Designated Nationals List individual and entities from:
- Rwanda, notably the Rwanda Defence Force, for supporting human rights abuse in the Democratic Republic of the Congo;
- Sudan as a result of recent designation as a Foreign Terrorist Organization;
- Turkey and Indonesia as a result of being designated as sham organizations that directly fund Hamas, a Foreign Terrorist Organization;
- N. Korea because they systematically defrauded U.S. persons to fund N. Korea’s Weapons of Mass Destruction Programs;
- Canada, Lebanon, Poland, Slovenia, and Syria for laundering and raising funds for Hizballah, a Foreign Terrorist Organization.
Detailed information regarding the OFAC can be found at https://ofac.treasury.gov/recent-actions.
LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE MARCH 2026 Read More »
The Compliance Illusion Why Companies Miss the Risks Sitting Right in Front of Them
By George Canovas, Vice President Compliance, FD Associates
Over the past 35 years, FD Associates has seen just about every version of an export control failure.
Not every compliance failure looks the same. Some companies lack a real program altogether. Others have policies, training, and approvals in place, but still fail because they rely on information that is never independently verified.
What is becoming more visible is not just enforcement activity, but how predictable the underlying pattern has become, even inside organizations that consider themselves compliant.
A recent indcitment of three individuals revealed a significant diversion of advanced US AI enabled servers worth billons of US dollars to China involving the co-founder of the company, who was also a board member and Senior Vice President of Business Development, its office in Taiwan and a third party broker. The FBI described a familiar set of tactics, false documentation, layered intermediaries, and even staged audit environments designed to pass inspection.
What stands out is not how sophisticated the scheme was, but how closely it mirrors structures FD Associates has seen in compliance reviews and audits over the years. The details change, but the underlying mechanics often remain the same.
The Pattern Behind the Headlines
If you take a step back from the headlines and look at how this AI computer diversion unfolded, the structure becomes clear. In this case, a US manufacturer was selling high performance AI servers that required an export license from the Department of Commerce for export to China. Instead of shipping directly, orders were placed through a company in Southeast Asia that did not require an export license and that company was presented as the end user.
Those servers moved through legitimate channels and were delivered as expected. On paper, everything aligned. The destination was permissible, the documentation was in order, and internal approvals for the transaction were obtained.
However, it was from this point that the transaction changed.
The servers were repackaged and redirected. As it turns out, the end user on paper was really a false intermediary and the real end user was in China. The documentation that supported the transaction had been structured to pass internal review, not to reflect reality.
At the same time, when both internal and government inspections were expected, dummy servers were staged to create the appearance that the equipment remained in place. Meanwhile, the actual systems had already moved to their final destination.
Communication between the parties took place outside normal channels, i.e., outside of company emails in encrypted messaging apps and the illegal diversion structure became more aggressive over time, eventually moving significant volumes of controlled technology.
None of this is particularly complex. But clearly it is effective and it is repeatable. Step back from the specifics and the pattern becomes obvious. A legitimate destination is used as a front door. Intermediaries are layered in to create distance from the actual end user. Documentation tells a clean and consistent story, while the logistics chain operates outside the exporters visibility.
By the time anyone looks closely, or even looks at all, the product is already somewhere it was never supposed to be. As mentioned, these are pretty consistent diversion playbook moves, and ones we have seen play out many times in the past.
When dealing in a high risk area such as AI computers, heightened awareness should have prevailed among the C-Suite and functional department leads.
When Everything Looks Right on Paper
In many of these situations, the company involved does not believe it has a compliance issue, in fact, they indicate they have a robust compliance program. There are policies in place, training and there are approval processes that appear to function as intended.
The bottom line is that on paper, the system works. The problem is, and this is important to focus on, that these systems are designed to validate the information they receive. When that information is incomplete, structured, or intentionally misleading, the outcome still appears clean.
We have seen transactions where the stated consignee was not the real end user, where the destination country was technically correct but only temporary, and where intermediaries were involved but never fully understood. In each case, the documentation aligned because it was built to align.
The compliance program did not fail in a traditional sense, it operated on a version of reality that was not accurate.
Where Companies Consistently get Exposed
After enough of these reviews, the same pressure points start to surface.
Third country routing is often treated as low risk, particularly when the initial destination does not require a license. What happens after delivery is assumed rather than verified. Intermediaries are accepted based on familiarity or past dealings, without a clear understanding of who they represent or how they operate within the transaction.
Audits tend to focus on whether documentation is complete and consistent, rather than whether it reflects what actually occurred. Red flags are noticed, but not always escalated in a way that changes the outcome. And in many cases, compliance is brought in after the structure of the transaction has already been set, rather than at the point where decisions are being made.
None of these issues are unusual. That is what makes them so difficult to detect.
The Uncomfortable Part
What makes cases like this resonate is not how unusual they are, but how familiar the underlying patterns feel. Many organizations will recognize elements of this in their own operations, whether they acknowledge it or not. Not at the same scale or with the same intent; but, the structure is often there and structure is what determines outcome.
In most cases, no one thinks they are doing anything wrong. The transaction looks reasonable. The customer seems legitimate. The paperwork is complete. Each step, on its own, makes sense. That is exactly why it gets through.
The best diversions work the same way good magic trick works. They are not about hiding everything. They are about controlling where you look.
- Your attention is on the paperwork, so the paperwork is clean.
- Your attention is on the stated destination, so the destination appears compliant.
- Your attention is on the approval process, so the approvals are in place.
While that is happening, something else is moving just outside that line of sight. Like in all organizations, the process is a checks-and-balances approach where everything is being reviewed in pieces or in steps. Each document checks out, each approval is based on what is presented, and each person is looking at their part of the process. It all checks out.
But what is clear is that no one is seeing the full picture, and by the time someone does, the product has already moved. This is what makes these situations so difficult to catch in real time. Everything is happening at normal speed, and each step looks reasonable on its own.
It is only when you slow down what happened, like an instant replay in sports, that the details become visible. In real time, the play looks clean, not out of bounds. But when it is replayed frame by frame, you start to see what was missed, the slight shift, the extra movement, the moment where the catch occurred out of bounds – something does not line up.
The best diversion schemes work the same way. In real time, the transaction looks complete and consistent. Only when you step back and reconstruct the full sequence do the gaps begin to appear. By then, the outcome is already decided.
The risk is not always in one obvious place. It lives in the gaps between what is documented and what is actually happening, and those gaps are easy to miss when everything is moving as expected. Something that most compliance programs are not designed to catch and this is the reason these situations keep repeating. Not because they are hidden, but because they look normal.
What Actually Works
So, how are these types of issues addressed, you may be wondering. Well, using traditional compliance corrective measures will not address these issues. Again, compliance programs are structures to address company process failures. In these types of cases it’s not about adding more policies or expanding training programs.
What tends to make a difference is how information is validated and how decisions are challenged. That includes independently verifying end use and end user, understanding the full transaction chain rather than just the immediate counterparty, and testing transactions in a way that goes beyond document review.
It also requires a clear separation between commercial pressure and compliance decision making, along with escalation paths that do more than record concerns and actually influence outcomes.
This is less about building a larger compliance program and more about building one that can see what is actually happening.
Final Thought
If there is one consistent lesson across the cases that FD Associates has seen over the years, it is this:
The biggest risk is not what companies do not know (although this is obviously important), it is what they believe to be true, but have never independently verified.
In real time, everything looks right using our normal compliance program lens. The transaction moves forward, all the paperwork aligns and the approvals are in place. There is no obvious reason to stop.
It looks like a clean play.
But as we have discussed, the best diversion schemes work like a well executed play that only reveals itself on replay. At full speed, nothing stands out. It is only when you slow it down and look at the full sequence do the details start to show. By then, it is too late.
From our experience, this is where most compliance programs begin to break down. Not because there are no rules, and not because there is no process, but because there is a belief that what is being seen reflects what is actually happening. As we note here, and in many other cases, it does not. And that gap, between what appears to be true and what is actually happening, is where serious compliance failures live.
If these issues resonate, maybe it is time to take a closer look at your compliance process before you need the replay.
The Compliance Illusion Why Companies Miss the Risks Sitting Right in Front of Them Read More »