LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE DECEMBER 2025
This newsletter is a listing of the latest changes in export control regulations through December 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
Department of State, Directorate of Defense Trade Controls (DDTC)
DDTC Published Redlined ITAR Regarding Cyprus And Cambodia Changes To The ITAR
December 2, 2025: Effective October 1 and November 7, 2025, the U.S. Department of State revised ITAR section 126.1 and suspended Cyprus’ status as a proscribed destination (90 FR 43388, Sept. 9, 2025) and removed Cambodia from the list of proscribed destinations (90 FR 50489, Nov. 7, 2025), respectively. To assist users of the ITAR, the U.S. Department provided a link to the updated ITAR Reorg redline, including all amendments made by those rulemakings. Those changes are identified in the reorg redline by identifier “Rev.17”.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=9c52bc864761f2d027972464336d43d0
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DDTC Launched A New AI-Enabled Virtual Agent
December 19, 2025: DDTC launched a new AI-Enabled Virtual Agent, available on the DDTC public website. This tool is designed to support defense industry users by providing 24/7 access to IT assistance.
The Virtual Agent leverages artificial intelligence to help you quickly find answers to common IT questions and search the DDTC IT Knowledge Base for relevant IT information and resources. This makes it easier to resolve routine IT issues without delay.
If your inquiry requires additional expertise, the Virtual Agent can connect you to a live support agent during business hours - Monday through Friday (excluding Federal holidays), 8:00 a.m. to 5:00 p.m. (EST).
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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December 22, 2025: On December 10, 2024, the Department issued a final rule regarding ITAR registration fees, effective January 9, 2025. In that rule, the Department announced a one-year initiative providing a Tier 1 registration fee discount and directing readers to our website for further information. The Department announced the extension of that initiative beyond January 9, 2026. Tier 1 registrants renewing or initiating registration on or after January 9, 2026, may continue to request the discount in accordance with those instructions. The Department will be publishing a Federal Register document providing additional direction regarding the discount.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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The U.S. Department of State Revised the ITAR AUKUS Exemption At 22 CFR § 126.7
December 30, 2025: 90 Fed. Reg. 61053: The Department of State published a final rule in the Federal Register effective the same day (90 FR 61053). This rule amends the International Traffic in Arms Regulations (ITAR) to further facilitate defense trade between and among Australia, the United Kingdom, and the United States. This rule finalizes the interim final rule 89 FR 67270, Aug. 2024, with amendments to refine the existing § 126.7(a) exemption introduced by that rule and create a new exemption in § 126.7(c) for certain reexports, retransfers, or temporary imports in support of the armed forces of Australia, the United Kingdom, or the United States.
Key Updates to the ITAR § 126.7 Exemptions
Expanded the definition of Authorized Users at § 126.7(b)(2), to state that the transferor, recipient, or broker must be:
- S. persons registered with the applicable Directorate of Defense Trade Controls (DDTC) registration pursuant to §§ 122.1 and 129.3 and eligible under § 120.16. The amendment did not change this section of the regulations;
- S. government, Australian federal-level, or UK national-level departments or agencies. This is a key change as such Australian federal-level and UK national level departments or agencies no longer need to be listed in DECCS as Authorized Users; or
- Australian or UK Authorized Users identified in the Defense Export Control and Compliance System (DECCS) (after having completed an enrollment process initiated through their respective national-level governments) The amendment did not change this section of the regulations.
Note: Non-U.S. Person Brokers must be registered with DDTC pursuant to § 129.3, eligible under § 120.16, and identified on the Authorized User List in DECCS.
Addition of §§ 126.7(c) and 126.7(d)
New sections § 126.7(c) and (d) were added to the exemption pursuant to this final rule.
Reexports, retransfers, or temporary imports in support of the armed forces of Australia, the United Kingdom, or the United States were added as § 126.7(c). The requirements and limitations to § 126.7(c) were added as § 126.7(d), which include that the defense article must have been originally exported via a license or other approval, and that the transferor is under contract with and either directly embedded with or operating alongside the armed forces of Australia, the United Kingdom, or the United States to provide direct on-site support or for returning the defense articles used in on-site support to Australia, the United Kingdom, or the United States.
Other Changes in the Final Rule
The rule revises § 126.18(e)(2), for the foreign persons to vet their dual/third country national employees, to align with the updates in § 126.7(b)(2)(ii) and (iii).
https://www.federalregister.gov/documents/2025/12/30/2025-23998/international-traffic-in-arms-regulations-exemption-for-defense-trade-and-cooperation-among and https://www.pmddtc.state.gov/sys_attachment.do?sys_id=611596cb9702b2d067b1791ad053af16
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December 30, 2025: The Department of State updated its ITAR Reorg I – Redline document, Revision 18, to reflect amendments made by the final rule, referenced above, that amended the AUKUS exemption at 22 CFR § 126.7.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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DDTC Frequently Asked Questions (FAQs)
Q: I've received a letter, apparently unrelated to any voluntary disclosure I previously filed, with questions from DDTC asking for information. What should I do?
A: If DDTC reached out to you with questions regarding a potential violation that you have not previously reported through a voluntary disclosure, please submit a complete and detailed response, attaching any requested or otherwise relevant documentation following the format and procedures for disclosures outlined in ITAR § 127.12 and reference the DDTC letter and the DTCC case number therein. This is referred to as a “Directed Disclosure.”
Q: I believe I may have violated the AECA or the ITAR. Am I required to disclose the violation to DDTC?
A: The ITAR mandates disclosures of certain types of violations. In particular, disclosures are required in certain cases involving (1) countries listed in ITAR § 126.1 (see ITAR §§ 126.1(e)(2), 126.16(h)(8), and 126.17(h)(8)), and (2) unreturned temporary exports of personal protective gear (see ITAR § 123.17(j)). Failure to disclose in such cases may itself constitute a violation of the ITAR.
For all other types of suspected violations, DDTC strongly encourages voluntary disclosure pursuant to ITAR § 127.12 by the party that may have committed a violation. DDTC may consider a voluntary disclosure a mitigating factor in determining the administrative penalty, if any, that should be imposed. Failure to disclose 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 the violation. DDTC views voluntary disclosures as a positive step toward improving ITAR compliance.
Q: I am aware of a potential ITAR violation that I did not commit, and the ITAR does not require that I disclose the violation to DDTC. Should I submit a voluntary disclosure?
A: DDTC strongly encourages the submission of tips by any person with information about another party’s potential violation of any export control provision of the AECA, the ITAR, or any order, license, or other authorization issued by the State Department under the AECA.
DDTC encourages a party submitting a tip to provide as much detail about the potential violation as possible. The process, information, and documentation described in ITAR § 127.12 may be helpful in assembling and providing a comprehensive and actionable report. DDTC treats such tips as confidential.
If you would like to report a ITAR violation that you did not commit, you can submit a tip (and request confidentiality, if appropriate) by accessing the DDTC website “Contact Us” page at this link: https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_contact_us,” then scroll down to “Contact the DDTC Response Team,” and click the “Email” button. The subject line of your email should clearly describe the submission as a notification to DDTC of a potential violation by a third party, rather than a voluntary disclosure. For more information, please refer to the “Report a Violation” page on DDTC’s website.
Q: How much time do I have to submit a voluntary disclosure?
A: Any person submitting a voluntary disclosure pursuant to ITAR § 127.12 should initially notify DDTC immediately after a violation is discovered and then, if warranted, conduct a thorough review of all defense trade transactions where a violation is suspected (see ITAR § 127.12(c)(2) for requirements). If submitting an initial notification, which does not contain all the information required of a full disclosure, the disclosing party has sixty (60) calendar days from the date of the initial notification to conduct a thorough review of all defense trade-related activities to submit a full disclosure.
Q: What should be included in a voluntary disclosure?
A: A detailed list of the information and documentation to include in a voluntary disclosure submission is provided in ITAR § 127.12(c)-(e). Voluntary disclosure submissions should also include: a first page with the disclosing party’s letterhead; the disclosing party’s contact information (including email address); documentation substantiating any claims made within the submission (e.g., proof of corrective actions, relevant compliance procedures in effect at the time the violation occurred, etc.); and a certification, signed by an empowered official (see ITAR § 120.67) or a senior officer, stating that all of the representations made in connection with the voluntary disclosure submission are true and correct to the best of that person’s knowledge and belief.
Moreover, if the disclosing party wishes to authorize DDTC to communicate directly with a third-party representative, such as a consultant or outside counsel, an empowered official or senior officer of the disclosing party should provide DDTC with a signed note on company letterhead identifying: (1) the name and full contact information of the third-party representative, and (2) the third-party representative’s relationship to the disclosing party. Please note that the third-party representative may not make the certification required by ITAR § 127.12(e) on behalf of the disclosing party.
For more information, please refer to the “Report a Violation” page on DDTC’s website.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notified Congress of Potential FMS Sale To The Kingdom Of Saudi Arabia
December 1, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Kingdom of Saudi Arabia of Blanket Order Training and related equipment for an estimated cost of $500 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Kingdom of Saudi Arabia has requested to buy blanket order aviation training services for the Royal Saudi Land Forces Aviation Corps (RSLFAC) from the U.S. Army. The following non-MDE items will be included: initial through advanced rotary-wing flight and maintainer training for personnel of the (RSLFAC) under sponsorship of the U.S. Army Training and Doctrine Command (TRADOC). The training will be conducted by U.S. Army instructors on the AH-64E Apache, CH-47F Chinook, UH-72A Lakota, and UH-60L/M Black Hawk Helicopters. The estimated total cost is $500 million.
This training will be provided at various CONUS based U.S. Army training sites under sponsorship of the U.S. Army Training and Doctrine Command (TRADOC). At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To The Kingdom Of Saudi Arabia
December 1, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Kingdom of Saudi Arabia of Cooperative Logistics Supply Support Arrangement Program, Foreign Military Sales Order II Case and related equipment for an estimated cost of $500 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Kingdom of Saudi Arabia has requested to buy a Cooperative Logistics Supply Support Arrangement (CLSSA) Foreign Military Sales Order (FMSO) II case to requisition orders for centrally managed spares and repair parts. This case supports the Royal Saudi Land Forces Aviation Corps’ UH-60A/L/M Black Hawk utility helicopters; AH-64A/D/E Apache attack helicopters; CH-47F Chinook cargo helicopters; Schweizer 333 helicopters; and Aerial Scout helicopters; and other related elements of logistics and program support. The estimated total cost is $500 million.
There are no principal contractors involved with this potential sale. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Bahrain
December 1, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Bahrain of F-16 Sustainment and related equipment for an estimated cost of $445 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale.
The Government of Bahrain has requested to buy aircraft components; missile containers; radar receiver component parts; guidance and control section spares; weapons system support; ground handling equipment; and instruments and lab equipment that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales case, valued at $47 million ($0 in major defense equipment), included major and minor modifications; Computer Program Identification Numbers (CPINs); aircraft maintenance support equipment; launcher spare parts and support equipment; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; studies and surveys; transportation support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $445 million.
The proposed sale of this equipment and support will not alter the basic military balance in the region.
The principal contractors will be General Electric Aerospace, located in Evendale, OH; and Lockheed Martin Aeronautics, located in Fort Worth, TX. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Canada
December 4, 2025: December 4, 2025 - The State Department made a determination to approve a possible Foreign Military Sale to the Government of Canada of Air Strike Weapons and related equipment for an estimated cost of $2.68 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Canada has requested to buy up to seven hundred fifty (750) GBU-39 practice bombs inert with fuzes; up to one hundred (100) GBU-39 Guided Test Vehicles (GTVs); up to one hundred (100) MK-82 inert filled bombs; up to two hundred twenty (220) 2,000-lb BLU-117 General Purpose (GP) bombs; up to one hundred forty-six (146) I-2000 penetrator warheads; up to three thousand four hundred fourteen (3,414) BLU-111 500-lb GP bombs; up to three thousand one hundred eight (3,108) GBU-39 Small Diameter Bomb Increment I (SDB-I) bombs; up to five thousand three hundred thirty-two (5,352) KMU-572 Joint Direct Attack Munition (JDAM) guidance sets; up to three hundred ninety-six (396) KMU-556 JDAM guidance sets; up to one hundred forty (140) KMU-557 JDAM guidance sets; up to two thousand four (2,004) GBU-53 SDBs – Increment II (SDB-II); and up to one hundred (100) GBU-53 SDB-II GTVs. The following non-MDE items will also be included: FMU-139 fuze systems; FMU-167 Hard Target Void Sensing Fuzes (HTVSF); DSU-38 laser illuminated target detectors for GBU-54; practice bombs; ammunition tools and special equipment; major and minor modifications equipment; spare and repair parts, consumables and accessories, and repair and return support; weapons and weapon support equipment; test equipment; training aids, devices, and spare parts; classified and unclassified software and software support; classified and unclassified publications and technical documentation; U.S. Government and contractor technical, engineering, and logistics personnel services; and other related elements of logistics and program support. The estimated total cost is $2.68 billion.
The principal contractors will be The Boeing Company, located in Arlington, VA; and RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To South Korea
December 5, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Republic of Korea of GBU-39/B Small Diameter Bombs-Increment I (SDB-I) and related equipment for an estimated cost of $111.8 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Republic of Korea has requested to buy an additional six hundred twenty-four (624) GBU-39/B Small Diameter Bombs (SDB-I) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $18.8 million ($15.4 million in major defense equipment (MDE)), included three hundred eighty-seven (387) GBU-39/B SDB-Is; aircraft components, spares, and accessories; explosive charges, devices, propellants, and components; spare parts, consumables and accessories, and repair and return support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $111.8 million.
The principal contractor will be The Boeing Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Italy
December 5, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Italy of Joint Air-to-Surface Standoff Missiles with Extended Range and related equipment for an estimated cost of $301 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Italy has requested to buy one hundred (100) AGM-158B/B-2 Joint Air-to-Surface Standoff Missiles with Extended Range (JASSM-ER). The following non-MDE items will also be included: JASSM classified test equipment and containers; KGV-135A encryption devices; spare and repair parts, consumables and accessories, and repair and return support; weapon system support and software; classified and unclassified software; classified and unclassified publications and technical documentation; transportation support; site surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $301 million.
The principal contractor will be Lockheed Martin, located in Orlando, FL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Denmark
December 5, 2025: The State Department made a determination approving a possible Foreign Military Sale to the Government of Denmark of AIM-120C-8 Advanced Medium Range Air-to-Air Missiles and related equipment for an estimated cost of $730 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Denmark has requested to buy two hundred (200) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM) and three (3) AIM-120-C8 AMRAAM guidance sections. The following non-major defense equipment items will also be included: AMRAAM control sections, containers, and support equipment; spare parts, consumables and accessories, and repair and return support; weapons software and support equipment; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; transportation support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $730 million.
The principal contractor will be RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations.
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DSCA Notified Congress of Potential FMS Sale To Denmark
December 5, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Denmark of Integrated Battle Command System with Indirect Fire Protection Capability and related equipment for an estimated cost of $3.0 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Denmark has requested to buy twenty-four (24) All Up Round Magazine (AUR-M); eight (8) Indirect Fire Protection Capability Increment 2 launchers; two (2) Sentinel A4 radars and Integrated Battle Command System (IBCS); two (2) IBCS Engagement Operations Centers; two (2) IBCS Integrated Collaborative Environments; and six (6) IBCS Integrated Fire Control Network relays. The following non-Major Defense Equipment items will also be included: reload vehicles; communications equipment, including, but not limited to, AN/PSN-13A Defense Advanced Global Positioning System receivers, AN/PYQ-10A Simple Key Loaders, AN/VRC-92F radio sets, RT-1523F receiver-transmitters, AN/TPX-61 interrogator set, AN/TPX-57A(V)1 Identification Friend or Foe (IFF) devices, KG-250X Inline Network Encryptors, and KIV-77 encryptors; tools and test equipment; support equipment; generators; publications and technical documentation; training equipment, including the Air Defense Reconfigurable Trainer; spare and repair parts; personnel training; Technical Assistance Field Team support; U.S. Government and contractor technical, engineering, and logistics support services; Systems Integration and Checkout; field office support; and other related elements of logistics and program support. The estimated total program cost is
$3.0 billion.
The principal contractors will be RTX Corporation, located in Arlington, VA; Lockheed-Martin, located in Syracuse, NY; Leidos Inc., located in Reston, VA; and Northrop Grumman, located in Falls Church, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Lebanon
December 5, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Lebanon of M1085A2 and M1078A2 Medium Tactical Vehicles and related equipment for an estimated cost of $90.5 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Lebanon has requested to buy 5-ton M1085A2 Medium Tactical Vehicles (MTVs) without winch; 2.5-ton M1078A2 MTVs without winch; spare and repair parts; publications and technical documentation; personnel training and training equipment; technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $90.5 million.
The principal contractor will be Oshkosh Defense, located in Oshkosh, WI. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Belgium
December 8, 2025: The State Department made a determination approving a possible Foreign Military Sale to the Government of Belgium of Hellfire missiles and related equipment for an estimated cost of up to $79 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Belgium has requested to buy up to two hundred forty (240) Hellfire missiles (AGM-114R2). The following non-MDE items will also be included: U.S. Government and contractor engineering, technical, and logistics support services; support equipment; communications and training equipment; ammunition, spare parts, consumables, accessories, and repair and return support; facility design; classified and unclassified publications; technical documentation; personnel training and training equipment; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $79 million.
The principal contractor will be Lockheed Martin Corporation, located in Troy, AL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Lebanon
December 16, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Lebanon of M1151A1 High Mobility Multi-Purpose Wheeled Vehicles and related equipment for an estimated cost of $34.5 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Lebanon has requested to buy an additional ninety (90) M1151A1 High Mobility Multi-Purpose Wheeled Vehicles (HMMWVs) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales case, valued at $12.26 million ($10.85 million in MDE), included fifty M1151A1 HMMWVs. This notification is for a combined total of one hundred forty HMMWVs. The following non-MDE items will also be included: RF-7850M-HH multiband handheld radio; Global Positioning System receiver; Quicklook electronic counter-countermeasures waveform; spare parts, repair parts, publications and technical documentation; training; U.S. Government and contractor engineering; technical and logistics support services; and other related elements of logistics and program support. The estimated total cost is $34.5 million.
The principal contractor will be AM General, located in South Bend, IN. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Japan
December 16, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Japan for Aegis Class Destroyer Support and related equipment for an estimated cost of $100.2 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Japan has requested to buy follow-on technical support of Aegis class destroyers, including Combat Systems Sea Qualification Trials (CSSQT); test and evaluation services; sustainment support and services; Aegis computer software updates; systems integration and testing, in-country and on-site engineering support; all necessary emergent engineering and technical support services; familiarization, operational support; system overhauls; system upgrades; on-the-job practical operations and maintenance; combat systems integration; development, testing, and installation of program patches; adaptation data and annual service agreements; fielding technical inquiries by the purchaser; operational integration and maintenance support; field service engineering; problem investigation; technical assistance; support solutions to technical problems arising from post-production; testing capabilities; supporting U.S. Government contractors and technical engineers; and other related elements of logistics and program support. The estimated total cost is $100.2 million.
The principal contractor will be Lockheed Martin Corporation, located in Moorestown, NJ. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of ALTIUS-700M and ALTIUS-600 Systems and related equipment for an estimated cost of $1.1 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy the following non-MDE items: ALTIUS-700M system loitering munitions integrated with full-motion video and an infrared gimbal seeker/tracker as well as assured position, navigation, timing, and resilient communications systems, and an integrated warhead assembly with energetics and canisters; inert 700M systems for training use only; ALTIUS-600 intelligence, surveillance, and reconnaissance systems integrated with command and control radio, multi-constellation Global Navigation Satellite System module, electro-optical/long-wave infrared camera gimbal, and canister launchers; associated support; solid metal training rounds; spares; ALTIUS trailers; ground control systems; battery chargers; operator and maintenance training; operator, maintenance, and training manuals; technical manuals; maintenance tool kits and test sets; logistics and fielding support; testing support; technical assistance including engineering services; program management; transportation; site surveys; facility, logistics, and maintenance evaluations; quality assurance and de-processing team support; field service support; and other related elements of logistics and program support. The total estimated cost is $1.1 billion.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of Harpoon Missile Repair Follow-on Support and related equipment for an estimated cost of $91.4 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy Harpoon radar seekers; return, repair and reshipment (RRR) of Naval Harpoon missiles; component parts and support equipment (SE); spare containers; personnel training and training equipment (both classified and unclassified); publications and technical documentation; U.S. Government and contractor technical support services; and other related elements of logistical and program support. The estimated total cost is $91.4 million.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of Javelin Missile System and related equipment for an estimated cost of $375 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy one thousand and fifty (1,050) Javelin FGM-148F missiles; ten (10) Javelin FGM-148F fly-to-buy lot acceptance missiles; and seventy (70) Javelin Lightweight Command Launch Units (LwCLU). The following non-MDE items will also be included: Javelin LwCLU basic skills trainers; missile simulation rounds; battery coolant units; interactive electronic technical manuals; Javelin operator manuals; lifecycle support; physical security inspection; spare parts; system integration and check out; technical assistance; tool kits; training; and other elements of logistics and program support. The estimated total cost is $375 million.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of Tube-launched, optically tracked, Wire-guided missile system and related equipment for an estimated cost of $353 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy one thousand five hundred forty-five (1,545) tube-launched, optically tracked, wire-guided (TOW) 2B BGM-71F-7-RF missiles; fourteen (14) TOW 2B BGM-71F-7-RF fly-to-buy lot acceptance missiles; and twenty-four (24) Improved Target Acquisition Systems. The following non-MDE items will also be included: lithium-Ion battery box; missile simulation rounds; ITAS High Mobility Multipurpose Wheeled Vehicle (HMMWV) mounting kits; engineering and logistics support services; technical assistance; training; and other related elements of logistics and program support. The estimated total cost is $353 million.
The principal contractor will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of High Mobility Artillery Rocket Systems and related equipment for an estimated cost of $4.05 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy eighty-two (82) M142 High Mobility Artillery Rocket Systems (HIMARS); four hundred twenty (420) M57 Army Tactical Missile System (ATACMS); seven hundred fifty-six (756) M31A2 Guided Multiple Launch Rocket System-Unitary pods (GMLRS-U); four hundred forty-seven (447) M30A2 Guided Multiple Launch Rocket System-Alternative Warhead pods (GMLRS-AW); thirty-nine (39) M1152A1 High Mobility Multipurpose Wheeled Vehicles (HMMWV); forty-five (45) International Field Artillery Tactical Data Systems (IFATDS). The following non-MDE items will also be included: M28A2 Low Cost Reduced Range Practice Rocket pods (LCRRPR); M249 machine gun; 5.56mm; M2A1 machine gun .50 CAL; M1084A2 truck, cargo, Family of Medium Tactical Vehicles (FMTV); Resupply Vehicles (RSV); M1089A2 truck, wrecker, FMTV, cargo, FMTV, RSV; M1095 Trailer, cargo, FMTV 5 Ton; Single Channel Ground and Airborne Radio System (SINCGRAS) Core Communication Management System (CCMS) in support of AN/VRC-90E and AN/VRC-92E; frequency-hopping radios; tool kits; test equipment; support equipment; technical documentation; spare parts; training; U.S. Government and contractor technical support; engineering and logistics support services; field office support; and elements of logistics/program support. The estimated total cost is $4.05 billion.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination approving a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of M107A7 Self-Propelled Howitzers and related equipment for an estimated cost of $4.03 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy sixty (60) M109A7 Self-Propelled Howitzers (SPH); sixty (60) M992A3 Carrier Ammunition Tracked (CAT) Vehicles; thirteen (13) M88A2 Recovery Vehicles (RV); four thousand and eighty (4,080) Precision Guidance Kits (PGK); and forty-two (42) International Field Artillery Tactical Data Systems (IFATDS). The following non-MDE items will also be included: M2A1 Machine Guns; M2A1 Spare barrels; Vehicle Internal Communication Systems training; Simple Key Loaders (SKLs); Defense Advanced Global Positioning System (GPS) Receiver (DAGR); M795 High Explosive 155mm projectiles; primers; fuzes; propellant charges; technical assistance; accessories; technical data; spare parts; new equipment training; contractor and United States Government services; tool kits; technical manuals; training devices; and other related elements of logistics and program support. The estimated total cost is $4.03 billion.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of AH-1W Helicopter Spare and Repair Parts and related equipment for an estimated cost of $96 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy AH-1W helicopter unclassified spare and repair parts; U.S. Government technical and logistics support services; and other related elements of logistics and program support. The estimated total cost is $96 million.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Taiwan
December 17, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States (TECRO) of Tactical Mission Network Software, Equipment, and Services and related equipment for an estimated cost of $1.01 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
TECRO has requested to buy a Tactical Mission Network (TMN). The following non-MDE items will be included: unmanned aerial systems; government and commercial off-the-shelf software; communications equipment; tool kits; test equipment; support equipment; technical documentation; training; spare parts; maintenance; telecommunication hosted/managed services; system security services and engineering support; analysis services; fusion services; safety and range support; cloud engineering support and services; U.S. Government and contractor technical support; engineering and logistics support services; warranty services; Systems Integration and Checkout (SICO); field office support; and other related elements of logistics and program support. The estimated total cost is $1.01 billion.
The principal contractor(s) will be selected through competitive procurements conducted by the U.S. Government in accordance with the Federal Acquisition Regulation. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To The NATO Support And Procurement Agency
December 18, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the NATO Support and Procurement Agency of Stinger Service Life Extension Program Components, Parts, and Services and related equipment for an estimated cost of $136.1 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale.
The NATO Support and Procurement Agency (NSPA) manages the Stinger Service Life Extension Program on behalf of Germany, Italy, and the Netherlands, and has requested to buy additional booster pellets; flight motors; gas generator cartridges; Stinger warheads sections; U.S. Government and contractor technical, engineering, and logistics support services; technical documentation; and other related elements of logistics and program support that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales case, valued at $50.7 million, included the following non-MDE items: booster pellets; flight motors; gas generators; Stinger warheads sections; and U.S. Government and contractor engineering and technical services. The estimated total cost is $136.1 million.
The principal contractors will be PTI Technologies Inc., located in Oxnard, CA; and L3 Harris, located in Camden, AR. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Spain
December 22, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Spain of F-404 Engine Fans and related equipment for an estimated cost of $200 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Spain has requested to buy an additional two hundred (200) F-404 engine fans that will be added to a previous implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case was valued at $98.80 million ($11.25 million in MDE) and included fifty (50) F-404 engine fans, associated computer power supply (CP-1325/APG-65) and receiver exciter (R-2089/APG-65) units, and associated services and equipment, spare parts, consumables, accessories, classified software delivery, and support. This notification is for a combined total of two hundred fifty (250) F-404 engine fans. The following non-MDE items will also be included: computer power supply (CP-1325/APG-65) and receiver exciter (R-2089/APG-65) units; associated services and equipment; spare parts, consumables, and accessories; repair and return support; classified software delivery and support; classified and unclassified publications; technical documentation; personnel training and training equipment; studies and surveys; Contractor Logistics Support (CLS); U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $200 million.
The F-404 engine fans will be transferred from United States Navy stock. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Denmark
December 22, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Denmark of Advanced Medium Range Air-to-Air Missiles – Extended Range and related equipment for an estimated cost of up to $951 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Denmark has requested to buy up to two hundred thirty-six (236) Advanced Medium Range Air to Air Missiles – Extended Range (AMRAAM-ER); and five (5) AIM-120-C8 guidance sections. The following non-MDE items will also be included: AMRAAM-ER load trainers, containers, and support equipment; spare parts, consumables and accessories, and repair and return support; weapons software and support equipment; classified software delivery and support; classified publications and technical documentation; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is up to $951 million.
The principal contractor will be RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations.
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DSCA Notified Congress of Potential FMS Sale To Poland
December 29, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Poland of Blanket Order Training and related elements of logistics and program support for an estimated cost of $200 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale.
The Government of Poland has requested to buy training aids and other related elements of logistics and program support that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $95 million ($0 in major defense equipment (MDE)), included personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. This notification is for a combined total of non-MDE training aids; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $200 million.
There is no principal contractor associated with this potential sale. Training will be provided by U.S. Government or contract vendors based upon requirements as they are determined. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Denmark
December 29, 2025: The State Department made a determination to approve a possible Foreign Military Sale to the Government of Denmark of Multi-Mission Maritime Patrol and Reconnaissance Aircraft P-8A with Indirect Fire Protection Capability and related equipment for an estimated cost of $1.8 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Denmark has requested to buy up to three (3) P-8A Patrol Aircraft; four (4) Multifunctional Distribution System Joint Tactical Radio Systems; four (4) Guardian Laser Transmitter Assemblies for the AN/AAQ-24(V)N; four (4) system processor replacements for AN/AAQ-24(V)N with Selective Availability Anti-spoofing Modules (SAASMs); and eight (8) LN-251 with Embedded Global Positioning Systems / Inertial Navigations Systems with SAASMs. The following non-MDE items will be included: Tactical Open Mission Software; electro-optical and infrared MX-20HD systems; NexGEN Missile Warning Sensors for the AN/AAQ-24(V)N; AN/AAQ-2(V) acoustic systems; AN/APY-10 radar systems; ALQ-213 early warning management systems; A/N UPX-43 interrogators; KIV-78A cryptographic appliqués; A/N APX-123A Identification Friend or Foe transmitters; AN/ARC-210 ultra high frequency / very high frequency radios; AN/ALE-47 Countermeasures Dispenser System (CMDS) programmers; KY-100M communications security (COMSEC) devices; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The total estimated cost is $1.8 billion.
The principal contractor will be The Boeing Company, located in Arlington, VA. At this time, the U.S. Government is unaware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations.
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U.S. Census Bureau
How to Resolve Common AES Response Messages
December 17, 2025: When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning. It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations.
To help you take the appropriate action, here is guidance on how to address one of the most frequent Response Messages that were generated in the AES for the previous month.
Response Code: 538
Narrative: Shipping Weight Must Be Greater Than Zero For MOT
Severity: Fatal
Reason: The Mode of Transportation Code reported was one that identifies a Vessel, Rail, Truck, or Air shipment and the Shipping Weight was not reported.
Resolution: When the Mode of Transportation is Vessel, Rail, Truck or Air, the Shipping Weight must be reported.
Verify the Mode of Transportation and Shipping Weight, correct the shipment and resubmit.
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
December 8, 2025: Two businessmen are now in custody for allegedly violating U.S. export control and smuggling laws. As part of the overall investigation, a Houston company and its owner also pleaded guilty to smuggling cutting-edge Artificial Intelligence (AI) technology out of the United States, and the United States has seized over $50 million in Nvidia technologies and cash.
According to court documents, Alan Hao Hsu, also known as Haochun Hsu, 43, of Missouri City, Texas, and his company, Hao Global LLC, both pleaded guilty to smuggling and unlawful export activities on Oct. 10, 2025. According to now unsealed court documents, between October 2024 and May 2025, Hsu and others knowingly exported and attempted to export at least $160 million worth of export-controlled Nvidia H100 and H200 Tensor Core graphic processing units (GPUs).
The H100 and H200 are high-speed GPUs used for AI applications and high-performance computing. They are designed to process massive amounts of data, advancing generative AI and large language models and accelerating scientific computing. These GPUs are used for both civilian and military applications.
Hsu and others falsified shipping paperwork, misclassifying the true nature of the goods and their recipients to conceal the ultimate destination of the GPUs. Hsu and Hao Global received more than $50 million in wire transfers that originated from the People’s Republic of China (PRC) to help fund the scheme. The GPUs were ultimately shipped to the PRC, Hong Kong and other destinations in violation of U.S. export laws.
At sentencing, Hsu faces up to 10 years in prison on Feb. 18, and Hao Global LLC faces a maximum penalty of twice the gross gain from the offense and a term of probation.
Also charged in relation to the scheme are two PRC natives. Benlin Yuan, 58, the chief executive officer of a Sterling, Virginia, IT services company, which is the U.S. subsidiary of a large PRC IT company based in Beijing, was arrested in Sterling, Virginia, on Nov. 28 and charged with conspiring to violation the Export Control Reform Act (ECRA) of 2018. Yuan is a Canadian citizen who resides in Mississauga, Ontario.
Fanyue Gong, also known as Tom Gong, 43, a PRC citizen who resides in Brooklyn, New York, is the owner of a New York technology company and was arrested in New York on Dec. 3. Gong was charged with conspiring to smuggle goods out of the United States.
According to charging documents, Gong and Yuan also independently conspired with employees of a Hong Kong-based logistics company and a China-based AI technology company to circumvent U.S. export controls.
If convicted, Yuan faces up to 20 years in prison for conspiring to violate ECRA and up to a $1 million fine. If convicted, Gong faces up to 10 years in prison for conspiring to smuggle goods out of the United States.
https://www.justice.gov/opa/pr/us-authorities-shut-down-major-china-linked-ai-tech-smuggling-network
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December 8, 2025: 90 Fed. Reg. 56717: On June 24, 2022, the then-Assistant Secretary of Commerce for Export Enforcement signed an order denying Siberian Airlines d/b/a S7 Airlines (“Siberian”) export privileges for a period of 180 days on the ground that issuance of the order was necessary in the public interest to prevent an imminent violation of the Regulations. The order was issued ex parte pursuant to Section 766.24(a) of the Regulations and was effective upon issuance. The temporary denial order was subsequently renewed on December 20, 2022, June 15, 2023, December 11, 2023, and December 6, 2024, respectively and were also effective upon issuance.
The Department of Commerce extended the denial order for Siberian for one year until December 8, 2026.
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December 9, 2025: 90 Fed. Reg. 57026: On June 24, 2022, the then-Assistant Secretary of Commerce for Export Enforcement signed an order denying Nordwind Airlines (“Nordwind”) export privileges for a period of 180 days on the ground that issuance of the order was necessary in the public interest to prevent an imminent violation of the Regulations. The order was issued ex parte pursuant to Section 766.24(a) of the Regulations and was effective upon issuance. The temporary denial order was subsequently renewed on December 20, 2022, June 15, 2023, December 11, 2023, and December 6, 2024, respectively, and were also effective upon issuance.
The Department of Commerce extended the denial order for Nordwind for one year until December 9, 2026.
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December 17, 2025: 90 Fed. Reg. 58544: On March 10, 2022, in the U.S. District Court for the District of Arizona, Arthur Ching-Fu Gau (“Gau”) was convicted of violating the International Emergency Economic Powers Act (50 U.S.C. 1701, et seq.) (“IEEPA”). Specifically, Gau was convicted of knowingly and willfully exporting and causing to exported from the United States to China technical data related to the electronic control unit of the legacy aircraft auxiliary power units, without having first obtaining the required license from the U.S. Department of Commerce. As a result of his conviction, Gau was sentenced him to 36 months of probation.
The U.S. Department of Commerce denied Gau's export privileges under the EAR for a period of 4 years from the date of Gau's conviction, March 10, 2026. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Gau had an interest at the time of his conviction.
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December 17, 2025: 90 Fed. Reg. 58548: On January 8, 2025, in the U.S. District Court for the Eastern District of New York, Nikolay Goltsev (“Goltsev”) was convicted of violating 50 U.S.C. 4819. Specifically, Goltsev was convicted of exporting and causing to be exported from the United States to Russia dual-use electronic components, items on the Commerce Control List and Common High Priority List, without having first obtained a license for such export from the U.S. Department of Commerce. Over the course of a year, Goltsev coordinated the export of over 300 shipments valued at over $7 million USD to Russian military-end users designated on BIS' Entity List and OFAC's SDN list. As a result of his conviction, Goltsev was sentenced to 40 months of imprisonment and one year of supervised release.
The U.S. Department of Commerce denied Goltsev's export privileges under the EAR for a period of 10 years from the date of Goltsev's conviction, January 8, 2035. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Goltsev had an interest at the time of his conviction.
https://www.federalregister.gov/documents/2025/12/17/2025-23122/order-denying-export-privileges
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December 17, 2025: 90 Fed. Reg. 58547: On March 13, 2025, in the U.S. District Court for the Northern District of Texas, Richard Shih (“Shih”), was convicted of violating 18 U.S.C. 371. Specifically, Shih conspired to illegally export U.S. goods from the United States to Chinese companies on the U.S. Department of Commerce's Entity List without required authorization. As a result of Shih's conviction, he was sentenced Shih to 60 months of probation.
The U.S. Department of Commerce denied Shih's export privileges under the EAR for a period of 10 years from the date of Shih's conviction, March 13, 2035. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Shih had an interest at the time of his conviction.
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December 17, 2025: 90 Fed. Reg. 58546: On August 1, 2022, in the U.S. District Court for the Central District of California, Marco Santillan, Jr. (“Santillan, Jr.”) was convicted of violating 50 U.S.C. 4819. Specifically, Santillan, Jr. was convicted of conspiring to violate the Export Administration Regulations by conspiring to export firearms and ammunition to Mexico. As a result of his conviction, the Court sentenced Santillan, Jr. to 57 months of imprisonment and three years of supervised release.
The U.S. Department of Commerce denied Santillan, Jr.'s export privileges under the EAR for a period of 10 years from the date of Santillan, Jr.'s conviction, August 1, 2032. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Santillan, Jr. had an interest at the time of his conviction.
https://www.federalregister.gov/documents/2025/12/17/2025-23119/order-denying-export-privileges
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December 17, 2025: 90 Fed. Reg. 58549: On January 8, 2024, in the U.S. District Court for the Central District of California, Marco Antonio Santillan Valencia (“Santillan”) was convicted of violating 50 U.S.C. 4819. Specifically, Santillan was convicted of conspiring to violate the Export Administration Regulations by conspiring to export firearms and ammunition to Mexico. As a result of his conviction, he was sentenced to eight months of imprisonment and three years of supervised release.
The U.S. Department of Commerce denied Santillan's export privileges under the EAR for a period of 10 years from the date of Santillan's conviction, January 8, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Santillan had an interest at the time of his conviction.
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December 17, 2025: 90 Fed. Reg. 58545: On October 31, 2023, in the U.S. District Court for the Southern District of Florida, Jose Raul Paredes Arispe (“Arispe”) was convicted of violating 18 U.S.C. 371 and 50 U.S.C. 4819. Specifically, Arispe was convicted of conspiring to smuggle and knowingly and willfully attempting to export and attempting to cause the export of firearms parts and firearms accessories from the U.S. to Bolivia without first having obtained the required license from the U.S. Department of Commerce. As a result of his conviction, he was sentenced 46 months of imprisonment and three years of supervised release.
The U.S. Department of Commerce denied Arispe 's export privileges under the EAR for a period of 10 years from the date of Santillan's conviction, October 31, 2033. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Arispe had an interest at the time of his conviction.
https://www.federalregister.gov/documents/2025/12/17/2025-23117/order-denying-export-privileges
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December 18, 2025: The United States collected over $53 million in settlement of a civil penalty lawsuit against Wanxiang America Corporation, a domestic importer for Wanxiang Group Corporation, a multinational conglomerate in the People’s Republic of China that manufactures and sells automotive components. The settlement marks the conclusion of nearly 10 years of contentious litigation, with the United States collecting all the lost revenue it sought and over $30 million in civil penalties.
The lawsuit brought by the United States against Wanxiang alleged that, for a period of five years, Wanxiang committed multiple violations of 19 U.S.C. § 1592 by making false statements to customs officials when importing automotive components, including tapered roller bearings and wheel hub assemblies incorporating tapered roller bearings. During that time, wheel hub assemblies were covered by a Department of Commerce antidumping duty order for tapered roller bearings from China, and except for specifically identified Chinese exporters, the China country-wide liquidation rate for goods covered by the antidumping duty order was 92.84%. Although it was aware of the antidumping duty order, Wanxiang falsely classified its imported wheel hub assemblies and failed to disclose that those importations were covered by the antidumping duty order. Wanxiang also misclassified multiple categories of automotive components, parts, and accessories under incorrect tariff provisions. These misrepresentations resulted in Wanxiang vastly underpaying the amount of customs and antidumping duties owed on its merchandise.
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
December 2, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $11,485,352 settlement with IPI Partners, LLC ("IPI") to settle its civil liability for 51 apparent violations of OFAC's sanctions against Russia. In 2017 and 2018, IPI solicited and received investments from Russian oligarch Suleiman Kerimov through a series of legal structures, and continued to maintain those investments for four years after OFAC designated Kerimov on April 6, 2018. The settlement amount reflects OFAC's determination that IPI's conduct was non-egregious and not voluntarily self-disclosed.
https://ofac.treasury.gov/recent-actions/20251202 and https://ofac.treasury.gov/media/934786/download?inline
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December 3, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned key affiliates of the designated Foreign Terrorist Organization (FTO), Tren de Aragua (TdA). Notably, this action includes the designation of Venezuelan entertainer Jimena Romina Araya Navarro (a.k.a. “Rosita”), who is part of a network of five persons affiliated with the entertainment industry that have provided material support to TdA. Rosita, for example, reportedly helped the notorious head of TdA, Hector Rusthenford Guerrero Flores (a.k.a. “Niño Guerrero”) escape from the Tocorón prison in Venezuela in 2012, and others in this network have laundered money for TdA leaders. OFAC is also sanctioned five additional key TdA affiliates and one entity located in South America.
The following individuals have been added to OFAC's SDN List:
- Aponte Cordova, Noe Manases of Venezuela;
- Araya Navarro, Jimena Romina of Venezuela and Colombia;
- Escobar Cabrera, Asdrubal Rafael of Venezuela;
- Espinal Quintero, Richard Jose of Venezuela;
- Guerrero Palma, Cheison Royer of Chile and Venezuela;
- Landaeta Hernandez, Eryk Manuel of Colombia and Venezuela; and
- Sevilla Arteaga, Kenffersso Jhosue of Colombia and Venezuela.
The following entities have been added to OFAC's SDN List:
- Eryk Producciones SAS, of Colombia;
- Global Import Solutions S.A., of Venezuela;
- Maiquetia Vip Bar Restaurant of Colombia; and
- Yakera Y Lane SAS of Colombia.
https://home.treasury.gov/news/press-releases/sb0327 and https://ofac.treasury.gov/recent-actions/20251203
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December 4, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a $7,139,305 penalty on Gracetown Inc., a property management company in New York, for violating OFAC’s Russia-related sanctions and for failing to report blocked assets to OFAC. This enforcement action, which resulted in a penalty near the statutory maximum, highlights the importance of following OFAC-issued guidance and the significant consequences that can occur from failing to do so.
OFAC’s investigation revealed that between April 2018 and May 2020, Gracetown received 24 payments totaling $31,250 on behalf of a company ultimately owned by sanctioned Russian oligarch Oleg Deripaska, despite having received explicit prior notice from OFAC that direct and indirect dealings with Deripaska were prohibited. Additionally, Gracetown failed to report blocked assets in its possession or control for over 45 months.
https://home.treasury.gov/news/press-releases/sb0328 and https://ofac.treasury.gov/media/934796/download?inline and https://ofac.treasury.gov/recent-actions/20251204_33
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December 4, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 128B, "Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia."
Russia-related General License 128B: All transactions prohibited by Executive Order (E.O.) 14024 involving Lukoil International GmbH (LIG) or any entity in which LIG owns, directly or indirectly, a 50 percent or greater interest, including Lukoil North America LLC and Lukoil Americas Corporation, (collectively, “LIG Entities”) that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of, physical retail service stations located outside of the Russian Federation, are authorized through 12:01 a.m. eastern daylight time, April 29, 2026.
All blocked accounts of LIG Entities may be used, debited, or credited for the transactions authorized above.
This general license does not authorize: (1) Any transactions prohibited by Directive 2 under E.O. 14024, Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions; (2) Any transactions prohibited by Directive 4 under E.O. 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation; (3) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR other than the LIG Entities described above, unless separately authorized; or (4) The transfer of funds to any person or account located in the Russian Federation.
Effective December 4, 2025, General License No. 128A, dated November 14, 2025, is replaced and superseded in its entirety by this General License No. 128B.
Additionally, OFAC published one new Russia-related Frequently Asked Question, FAQ 1225.
Question 1225: What activities do Russia-related General License 128B and General License 131A authorize related to Lukoil International GmbH (LIG)?
Answer: OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128B and GL 131A. The GLs are similar but have different expiration dates and terms as each serves a different purpose.
- To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. This GL expires on April 29, 2026.
- To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. This GL has a shorter duration as it expires on January 17, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128B and GL 131A expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131A. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128B and GL 131A authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.
Both GL 128B and GL 131A also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.
Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131A. Similarly, non-U.S. persons may rely upon GL 128B and GL 131A regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131A, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
https://ofac.treasury.gov/media/934791/download?inline and https://ofac.treasury.gov/recent-actions/20251204 and https://ofac.treasury.gov/faqs/1225
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December 9, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $1,092,000 settlement with an individual ("U.S. Person-1") to settle their civil liability for 122 apparent violations of OFAC sanctions against Russia. Between April 2018 and June 2022, U.S. Person-1 served as the fiduciary of the U.S.-based family trust of a sanctioned Russian oligarch. In that capacity, U.S. Person-1 dealt in the blocked property of, and provided prohibited services to, the oligarch. OFAC determined that U.S. Person-1's conduct was non-egregious and not voluntarily self-disclosed. The settlement amount also reflects U.S. Person-1's substantial cooperation with OFAC's investigation.
https://ofac.treasury.gov/recent-actions/20251209_33 and https://ofac.treasury.gov/media/934806/download?inline
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December 9, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on four individuals and four entities for their roles in fueling the civil war in Sudan, a conflict that has provoked the world’s worst ongoing humanitarian crisis. This transnational network—primarily composed of Colombian nationals and companies—recruits former Colombian military personnel and trains soldiers, including children, to fight for the Sudanese paramilitary group known as the Rapid Support Forces (RSF).
The following individuals have been added to OFAC's SDN List:
- Duque Botero, Mateo Andres, of Colombia and Spain;
- Munoz Ucros, Monicaof Colomibia;
- Oliveros Forero, Claudia Viviana of Colombia; and
- Quijano Becerra, Alvaro Andres of Colombia and the United Arab Emirates.
The following entities have been added to OFAC's SDN List:
- Comercializadora San Bendito S.A.S., of Colombia;
- International Services Agency S.A.S. of Colombia;
- Maine Global Corp S.A.S., of Colombia; and
- Talent Bridge, S.A. of Panama.
https://home.treasury.gov/news/press-releases/sb0330 and https://ofac.treasury.gov/recent-actions/20251209
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December 10, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 131A, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities."
General License 131A: All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the negotiation of and entry into contracts with Public Joint-Stock Company Oil Company Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “LIG Entities”) are authorized through 12:01 a.m. eastern standard time, January 17, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control (“contingent contracts”). Note: For purposes of this general license, the term “contingent contracts” includes executory contracts, executory pro forma invoices, agreements in principle, executory offers capable of acceptance such as bids or proposals in response to public tenders, binding memoranda of understanding, or any other similar agreement.
Except as provided below this general license, all transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG Entities are authorized through 12:01 a.m. eastern standard time, January 17, 2026.
All blocked accounts of LIG Entities may be used, debited, or credited for the transactions authorized.
This general license does not authorize: (1) The unblocking of any property blocked pursuant to any part of 31 CFR chapter V, except as authorized above; (2) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, other than blocked persons described in this general license, unless separately authorized; or (3) The transfer of funds to any person or account located in the Russian Federation.
Effective December 10, 2025, General License No. 131, dated November 14, 2025, is replaced and superseded in its entirety by this General License No. 131A.
https://ofac.treasury.gov/recent-actions/20251210 and https://ofac.treasury.gov/media/934801/download?inline
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December 11, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted Nicolas Maduro’s illegitimate regime in Venezuela, sanctioned three nephews of Maduro’s wife, Cilia Flores; a Maduro-affiliated businessman; and six shipping companies operating in Venezuela’s oil sector. Additionally, OFAC identified six associated vessels that have engaged in deceptive and unsafe shipping practices and continue to provide financial resources that fuel Maduro’s corrupt narco-terrorist regime.
The following individuals have been added to OFAC's SDN List:
- Campo Flores, Efrain Antonio of Venezuela;
- Carretero Napolitano, Ramon of Panama;
- Flores De Freitas, Franqui Francisco of Venezuela; and
- Malpica Flores, Carlos Erik of Venezuela.
The following entities have been added to OFAC's SDN List:
- Arctic Voyager Incorporated of the Marshall Islands;
- Full Happy Limited, of the Marshall Islands;
- Myra Marine Limited, of the Marshall Islands;
- Poweroy Investment Limited of the British Virgin Islands;
- Ready Great Limited, of the Marshall Islands; and
- Sino Marine Services Limited of the United Kingdom.
The following vessels have been added to OFAC's SDN List:
- Constance (3E2177) Vessel Registration Identification IMO 9237773; MMSI 352002009;
- Kiara M (3E2278) Vessel Registration Identification IMO 9285823; MMSI 352002348;
- Lattafa (3E2298) Vessel Registration Identification IMO 9245794;
- Monique (E5U5122) Vessel Registration Identification IMO 9311270; MMSI 518999141;
- Tamia (VRXC8) Vessel Registration Identification IMO 9315642; MMSI 477186300; and
- White Crane (HOA6213) Vessel Registration Identification IMO 9323429; MMSI 352003199.
https://home.treasury.gov/news/press-releases/sb0332 and https://ofac.treasury.gov/recent-actions/20251211
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December 15, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Belarus General License 13, "Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO."
Belarus General License 13: All transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (BSR), involving the following entities are authorized: (1) Joint Stock Company Belarusian Potash Company; (2) Agrorozkvit LLC; (3) Belaruskali OAO; or (4) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
This general license does not authorize: (1) The unblocking of any property blocked pursuant to any part of 31 CFR chapter V; or (2) Any transactions otherwise prohibited by the BSR, including transactions involving the property or interests in property of any person blocked pursuant to the BSR other than the blocked persons described above, unless separately authorized.
https://ofac.treasury.gov/recent-actions/20251215 and https://ofac.treasury.gov/media/934826/download?inline
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December 16, 2025: The Department of State designated Clan del Golfo as a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT).
Based in Colombia, Clan del Golfo is a violent and powerful criminal organization with thousands of members. The group’s primary source of income is cocaine trafficking, which it uses to fund its violent activities. Clan del Golfo is responsible for terrorist attacks against public officials, law enforcement and military personnel, and civilians in Colombia.
The following changes have been made to OFAC's SDN List:
Clan Del Golfo (A.K.A. Banda Criminal De Uraba; A.K.A. Clan Usuga; A.K.A. Gulf Clan; A.K.A. Los Autodefensas Gaitanistas De Colombia; A.K.A. Los Urabenos (Latin: Los Urabeños)), Colombia [Sdntk] [Illicit-Drugs-Eo14059]. -To- Clan Del Golfo (A.K.A. Banda Criminal De Uraba; A.K.A. Clan Usuga; A.K.A. Gulf Clan; A.K.A. Los Autodefensas Gaitanistas De Colombia; A.K.A. Los Urabenos (Latin: Los Urabeños)), Colombia; Secondary Sanctions Risk: Section 1(B) Of Executive Order 13224, As Amended By Executive Order 13886; Organization Type: Transnational Terrorist Group; Target Type Criminal Organization [SDNTK] [FTO] [SDGT] [ILLICIT-DRUGS-EO14059].
https://www.state.gov/releases/office-of-the-spokesperson/2025/12/terrorist-designations-of-clan-del-golfo/ and https://ofac.treasury.gov/recent-actions/20251216
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December 16, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $3,103,360 settlement with Exodus Movement, Inc. ("Exodus") to settle its potential civil liability for 254 apparent violations of OFAC’s sanctions on Iran. Between October 2017 and January 2019, Exodus provided customer support services to users in Iran which in certain instances helped such users access digital asset exchanges through Exodus's wallet software. The settlement amount reflects OFAC's determination that the apparent violations were not voluntarily self-disclosed and that 12 of the 254 apparent violations were egregious.
https://ofac.treasury.gov/recent-actions/20251216_33 and https://ofac.treasury.gov/media/934836/download?inline and https://ofac.treasury.gov/media/934831/download?inline
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December 17, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Cartel de Santa Rosa de Lima (CSRL), which derives the vast majority of its illicit revenue from fuel and oil theft in the Mexican state of Guanajuato. The violent conflict between CSRL and the notorious Mexican terrorist Cartel Jalisco Nuevo Generacion (CJNG) for control of fuel and oil in Guanajuato has made the state one of the deadliest in Mexico. CSRL’s activities also help enable a cross-border energy black market, undermine legitimate U.S. oil and natural gas companies, and deprive the Mexican government of critical revenue. OFAC also sanctioned Jose Antonio Yepez Ortiz, the leader of CSRL.
The following individual has been added to OFAC's SDN List:
- Yepez Ortiz, Jose Antonio of Mexico.
The following entity has been added to OFAC's SDN List:
- Cartel De Santa Rosa De Lima of Mexico.
https://home.treasury.gov/news/press-releases/sb0339 and https://ofac.treasury.gov/recent-actions/20251217
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December 17, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 55E, "Authorizing Certain Services Related to Sakhalin-2;" and Russia-related General License 115C, "Authorizing Certain Transactions Related to Civil Nuclear Energy."
Russia-related General License 55E: All transactions prohibited by the determination of November 21, 2022 made pursuant to section 1(a)(ii) of Executive Order (E.O.) 14071 (“Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin”) related to the maritime transport of crude oil originating from the Sakhalin-2 project (“Sakhalin-2 byproduct”) are authorized through 12:01 a.m. eastern daylight time, June 18, 2026, provided that the Sakhalin-2 byproduct is solely for importation into Japan.
Except as provided above, all transactions prohibited by E.O. 14024 involving Gazprombank Joint Stock Company (Gazprombank) or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, that are related to the Sakhalin-2 project, including such transactions involving Sakhalin Energy LLC, are authorized through 12:01 a.m. eastern daylight time, June 18, 2026.
Except as provided above, all transactions prohibited by the determination of January 10, 2025 made pursuant to section 1(a)(ii) of E.O. 14071 (“Prohibition on Petroleum Services”) that are related to the Sakhalin-2 project are authorized through 12:01 a.m. eastern daylight time, June 18, 2026.
This general license does not authorize:
(1) Any transactions prohibited by Directive 2 under E.O. 14024, Prohibitions Related to
Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain
Foreign Financial Institutions;
(2) Any transactions prohibited by Directive 4 under E.O. 14024, Prohibitions Related to
Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of
the Russian Federation, and the Ministry of Finance of the Russian Federation; or
(3) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities
Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person
blocked pursuant to the RuHSR, other than the blocked persons described in paragraph (b),
unless separately authorized.
Effective December 17, 2025, General License No. 55D, dated June 18, 2025, is replaced and superseded in its entirety by this General License No. 55E.
Russia-related General License 115C: All transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to civil nuclear energy are authorized through 12:01 a.m. eastern daylight time, June 18, 2026: (1) Gazprombank Joint Stock Company; (2) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (3) Public Joint Stock Company Bank Financial Corporation Otkritie; (4) Sovcombank Open Joint Stock Company; (5) Public Joint Stock Company Sberbank of Russia; (6) VTB Bank Public Joint Stock Company; (7) Joint Stock Company Alfa-Bank; (8) Public Joint Stock Company Rosbank; (9) Bank Zenit Public Joint Stock Company; (10) Bank Saint-Petersburg Public Joint Stock Company; (11) National Clearing Center (NCC); (12) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or (13) the Central Bank of the Russian Federation.
For the purposes of this general license, the term “related to civil nuclear energy” means transactions undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024.
Additionally, OFAC is amending eight Russia-related Frequently Asked Questions: FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216.
https://ofac.treasury.gov/recent-actions/20251217 and https://ofac.treasury.gov/media/934846/download?inline and https://ofac.treasury.gov/media/934851/download?inline
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December 18, 2025: OFAC issued two amended Russia-related Frequently Asked Questions, FAQ 1224 and 1225.
Question 1224: What negotiations does Russia-related General License 131A authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?
Answer: On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131A, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131A expires on January 17, 2026.
GL 131A does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131A must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.
As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.
OFAC may revoke GL 131A at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.
Question 1225: What activities do Russia-related General License 128B and General License 131A authorize related to Lukoil International GmbH (LIG)?
Answer: OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128B and GL 131A. The GLs are similar but have different expiration dates and terms as each serves a different purpose.
To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. This GL expires on April 29, 2026.
To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. This GL has a shorter duration as it expires on January 17, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128B and GL 131A expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131A. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128B and GL 131A authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.
Both GL 128B and GL 131A also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.
Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131A. Similarly, non-U.S. persons may rely upon GL 128B and GL 131A regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131A, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
https://ofac.treasury.gov/faqs/1224 and https://ofac.treasury.gov/faqs/1225 and https://ofac.treasury.gov/recent-actions/20251218_33
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December 18, 2025: Marco Rubio, Secretary of State, designated two International Criminal Court (ICC) judges, Gocha Lordkipanidze of Georgia and Erdenebalsuren Damdin of Mongolia, pursuant to Executive Order 14203, “Imposing Sanctions on the International Criminal Court.” These individuals have directly engaged in efforts by the ICC to investigate, arrest, detain, or prosecute Israeli nationals, without Israel’s consent, including voting with the majority in favor of the ICC’s ruling against Israel’s appeal on December 15.
The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued International Criminal Court-related General License 11, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on December 18, 2025;" and Iran-related General License S, "Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on December 18, 2025."
International Criminal Court-related General License 11: All transactions prohibited by the International Criminal Court-Related Sanctions Regulations (ICCSR), 31 CFR part 528, that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern standard time, January 17, 2026, provided that any payment to a blocked person is made into a blocked interest bearing account located in the United States, in accordance with the ICCSR: (1) Gocha Lordkipanidze; (2) Erdenebalsuren Damdin; or (3) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. This general license does not authorize any transactions otherwise prohibited by the ICCSR, including transactions involving any person blocked pursuant to the ICCSR other than the blocked persons described above, unless separately authorized.
Iran-related General License S: All transactions prohibited by Executive Order (E.O.) 13902 that are ordinarily incident and necessary to one or more of the following activities involving the blocked vessels or blocked persons listed in the Annex to this general license, and any entity in which the listed blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time, January 18, 2026, provided that any payment to a blocked person must be made into a blocked interest-bearing account located in the United States: (1) The safe docking and anchoring in any port, excluding ports located in Iran or the Russian Federation or Venezuela, or under the control of the Government of Iran or the Government of the Russian Federation or the Government of Venezuela, of the blocked vessels listed in the Annex to this general license (the “Blocked Vessels”); (2) The preservation of the health or safety of the crew of any of the Blocked Vessels; (3) Emergency repairs of any of the Blocked Vessels or environmental mitigation or protection activities relating to any of the Blocked Vessels; or (4) The delivery and offloading of cargo involving the Blocked Vessels, provided that the cargo is not of Iranian-origin and was loaded on or before December 18, 2025, and that the delivery and offloading of cargo does not occur at any port located in Iran or the Russian Federation or Venezuela, or under the control of the Government of Iran or the Government of the Russian Federation or the Government of Venezuela. Note: The authorization in paragraph (a) of this general license includes services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.
The following individuals have been added to OFAC's SDN List:
- Damdin, Erdenebalsuren of The Netherlands and Mongolia;
- Lordkipanidze, Gocha of The Netherlands and Georgia; and
- Sakr, Hatem Elsaid Farid Ibrahim of the United Arab Emirates and Egypt.
The following entities have been added to OFAC's SDN List:
- Adonis Shipping Inc, of the Marshall Islands;
- Agape Shipping Inc, of the Marshall Islands;
- Aleah Shipping Inc, of the British Virgin Islands;
- Arihant Shipping Inc., of Panama;
- Concord Shipping Inc., of the Marshall Islands;
- Darya Shipping Private Limited of India;
- Everest Sea Navigation SA of Liberia;
- Golden Gate Ship Management of India;
- Hemera Lines Inc., of the Marshall Islands;
- High Seas Petroleum LLC of the United Arab Emirates;
- J M A Shipping Inc., of Panama;
- Kurdos Shipping Inc., of Panama;
- M K A Shipping Inc., of the Marshall Islands;
- Maruti Shipping Inc., of the Marshall Islands;
- Phoenix Ship Management FZE of the United Arab Emirates;
- Qatrat Alnada Almasi Ship Management L.L.C., of the United Arab Emirates;
- Red Sea Ship Management LLC of the United Arab Emirates;
- Rukbat Marine Services CO of India;
- S M A Shipping Inc., of Panama;
- Sinostar Marine Group Limited of the Marshall Islands.
The following vessels have been added to OFAC's SDN List:
- Aether Sail (T8A4543) Vessel Registration Identification IMO 9277371; MMSI 511101256
- Arihant (T8A3376) Vessel Registration Identification IMO 9464156; MMSI 511100268;
- Auroura (3E3982) Vessel Registration Identification IMO 9262912; MMSI 352001225;
- Diana (6YWV8) Vessel Registration Identification IMO 9255945; MMSI 339000161;
- Flora Dolce (8PZQ8) Vessel Registration Identification IMO 9258595; MMSI 314001081;
- Foshan (3E2124) Vessel Registration Identification IMO 9404572; MMSI 352001366;
- Golden Eagle Vessel Registration Identification IMO 9255684; MMSI 341313001;
- Hemera (T8A4764) Vessel Registration Identification IMO 9263954; MMSI 511101408;
- Intan Premier (T8A5105) Vessel Registration Identification IMO 9358802; MMSI 511101645;
- J M A (E5U4180) Vessel Registration Identification IMO 9246487; MMSI 518998202;
- Kassia (3E2726) Vessel Registration Identification IMO 9409986; MMSI 352001708;
- Khadiga (T8A4125) Vessel Registration Identification IMO 9321469; MMSI 511100904;
- Kurdos (T8A5448) Vessel Registration Identification IMO 9236731; MMSI 511101920;
- Kurdos II (T8A4469) Vessel Registration Identification IMO 9453729; MMSI 511101194;
- Kurdos III (T8A5317) Vessel Registration Identification IMO 9380570; MMSI 511101819;
- M K A (E5U4496) Vessel Registration Identification IMO 9269403; MMSI 518998516;
- Majesty (E5U4288) Vessel Registration Identification IMO 9430715;
- Maruti (E5U4438) Vessel Registration Identification IMO 9546710; MMSI 518998458;
- Nebula Drift (T8A5231) Vessel Registration Identification IMO 9233973; MMSI 511101749;
- Nomiki (3E7581) Vessel Registration Identification IMO 9242443; MMSI 352004062;
- Ramya (8PZQ3) Vessel Registration Identification IMO 9363182; MMSI 314001076;
- S M A (E5U3873) Vessel Registration Identification IMO 9273002; MMSI 518100962;
- Sea Citrine VI (T8A4765) Vessel Registration Identification IMO 9207273; MMSI 511101409;
- Sea Rock Vessel Registration Identification IMO 9140451;
- Sea Wise (T8A3980) Vessel Registration Identification IMO 9224570; MMSI 511100774;
- Seamull (T8A3433) Vessel Registration Identification IMO 9204776; MMSI 511100317;
- Skylight (T8A4356) Vessel Registration Identification IMO 9330020; MMSI 511101102;
- Tidal Rhythm (3E6978) Vessel Registration Identification IMO 9297101; MMSI 352004719; and
- Voyager Haven (3E6786) Vessel Registration Identification IMO 9271896; MMSI 352004496.
https://www.state.gov/releases/office-of-the-spokesperson/2025/12/sanctioning-icc-judges-directly-engaged-in-the-illegitimate-targeting-of-israel/ and https://ofac.treasury.gov/media/934856/download?inline and https://ofac.treasury.gov/media/934861/download?inline
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December 19, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned several family members and associates of the Maduro-Flores family. This action further targets the narco-corruption structure that sustains Nicolás Maduro’s illegitimate regime, namely the familial networks of Carlos Erik Malpica Flores (Malpica Flores) and Ramon Carretero Napolitano (Ramon Carretero).
The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 5T, "Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After February 3, 2026."
Venezuela-related General License 5T: On or after February 3, 2026, all transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond that would be prohibited by subsection l(a)(iii) of Executive Order (E.O.) 13835 of May 21, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized.
This general license does not authorize any transactions or activities otherwise prohibited by the VSR, or any other part of 31 CFR chapter V. Effective December 19, 2025, General License No. 5S, dated June 20, 2025, is replaced and superseded in its entirety by this General License No. 5T.
Additionally, OFAC published an amended Venezuela-related Frequently Asked Question, FAQ 595.
The following individuals have been added to OFAC's SDN List:
- Carretero Napolitano, Roberto of Panama;
- Carretero Napolitano, Vicente Luis of Panama;
- Flores De Malpica, Eloisa of Venezuela;
- Hurtado Perez, Damaris del Carmen of Venezuela;
- Malpica Flores, Iriamni of Venezuela;
- Malpica Hurtado, Erica Patricia of Venezuela;
- Malpica Torrealba, Carlos Evelio of Venezuela.
https://home.treasury.gov/news/press-releases/sb0343 and https://ofac.treasury.gov/media/934866/download?inline and https://ofac.treasury.gov/recent-actions/20251219
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December 23, 2025: The U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury's Office of Foreign Assets Control, issued an amended Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria, to reflect the repeal of the Caesar Syria Civilian Protection Act of 2019 (Caesar Act).
https://ofac.treasury.gov/media/934736/download?inline and https://ofac.treasury.gov/recent-actions/20251223
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December 30, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted individuals and entities based in Venezuela and Iran, including a Venezuelan company that has contributed to Iran’s unmanned aerial vehicle (UAV) trade with Venezuela.
The following individuals have been added to OFAC's SDN List:
- Ghaffari, Mehdi of Iran;
- Qaysari, Erfan of Iran;
- Rezaei, Bahram of Iran;
- Rostami Sani, Mostafa of Iran;
- Urdaneta Gonzalez, Jose Jesus of Venezuela; and
- Zarepour Taraghi, Reza of Iran.
The following entities have been added to OFAC's SDN List:
- Empresa Aeronautica Nacional SA of Venezuela;
- Fanavari Electro Moj Mobin Company of Iran;
- Kavoshgaran Asman Moj Ghadir Company of Iran; and
- Pardisan Rezvan Shargh International Private Joint Stock Company of Iran.
https://home.treasury.gov/news/press-releases/sb0347 and https://ofac.treasury.gov/recent-actions/20251230
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December 31, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four companies for operating in Venezuela’s oil sector and identified four associated oil tankers as blocked property. These vessels, some of which are part of the shadow fleet serving Venezuela, continue to provide financial resources that fuel Maduro’s illegitimate narco-terrorist regime. Maduro’s regime increasingly depends on a shadow fleet of worldwide vessels to facilitate sanctionable activity, including sanctions evasion, and to generate revenue for its destabilizing operations. This action further signals that those involved in the Venezuelan oil trade continue to face significant sanctions risks.
The following entities have been added to OFAC's SDN List:
- Aries Global Investment LTD of China;
- Corniola Limited of China;
- Krape Myrtle CO LTD of China;
- Winky International Limited of China.
The following vessels have been added to OFAC's SDN List:
- Della (VRUB7) Vessel Registration Identification IMO 9227479; MMSI 477714500;
- Nord Star (3E7463) Vessel Registration Identification IMO 9323596; MMSI 352003296;
- Rosalind Vessel Registration Identification IMO 9277735; and
- Valiant (VRXH3) Vessel Registration Identification IMO 9409247; MMSI 477206500.
https://home.treasury.gov/news/press-releases/sb0348 and https://ofac.treasury.gov/recent-actions/20251231
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