JUNE 2025 EXPORT CONTROLS AND COMPLIANCE UPDATES
This newsletter is a listing of the latest changes in export control regulations through June 30, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
Providing For The Revocation Of Syria Sanctions
June 30, 2025: By the authority vested in President Trump by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), the National Emergencies Act (50 U.S.C. 1601 et seq.) (NEA), the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (Public Law 108-175) (Syria Accountability Act), the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (Public Law 102-182, title III) (CBW Act), the Caesar Syria Civilian Protection Act of 2019, as amended (22 U.S.C. 8791 note) (Caesar Act), the Illicit Captagon Trafficking Suppression Act of 2023 (Public Law 118-50, div. P), and section 301 of title 3, United States Code, it is hereby ordered:
Section 1. Background. The United States is committed to supporting a Syria that is stable, unified, and at peace with itself and its neighbors. A united Syria that does not offer a safe haven for terrorist organizations and ensures the security of its religious and ethnic minorities will support regional security and prosperity. The Secretary of State and the Secretary of the Treasury have taken initial steps towards this goal through the issuance on May 23, 2025, of General License 25 and a waiver of sanctions under the Caesar Act.
Sec. 2. Policy. It is the policy of the United States to recognize that circumstances that gave rise to the actions taken in the Executive Orders described in section 3(a) of this order, related to the policies and actions of the former regime of Bashar al-Assad, have been transformed by developments over the past 6 months, including the positive actions taken by the new Syrian government under President Ahmed al-Sharaa. This order supports United States national security and foreign policy goals by directing additional actions, including the removal of sanctions on Syria, the issuance of waivers that permit the relaxation of export controls and other restrictions on Syria, and other actions to be taken by the Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce, as well as by other executive departments and agencies (agencies) of the United States, without providing relief to ISIS or other terrorist organizations, human rights abusers, those linked to chemical weapons or proliferation-related activities, or other persons that threaten the peace, security, or stability of the United States, Syria, and its neighbors.
Sec. 3. Revocation of Syria Sanctions. (a) Effective July 1, 2025, President Trump hereby terminates the national emergency declared in Executive Order 13338 of May 11, 2004 (Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria), and revoke that order, as well as Executive Order 13399 of April 25, 2006 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria), Executive Order 13460 of February 13, 2008 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria), Executive Order 13572 of April 29, 2011 (Blocking Property of Certain Persons with Respect to Human Rights Abuses in Syria), Executive Order 13573 of May 18, 2011 (Blocking Property of Senior Officials of the Government of Syria), and Executive Order 13582 of August 17, 2011 (Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria).
(b) Pursuant to section 202(a) of the NEA (50 U.S.C. 1622(a)), termination of the national emergency declared in Executive Order 13338, as modified in scope and relied upon for additional steps taken in Executive Order 13399, Executive Order 13460, Executive Order 13572, Executive Order 13573, and Executive Order 13582 shall not affect any action taken or pending proceeding not finally concluded or determined as of July 1, 2025, any action or proceeding based on any act committed prior to July 1, 2025, or any rights or duties that matured or penalties that were incurred prior to July 1, 2025.
Sec. 4. Accountability for the Former Regime of Bashar al‑Assad. President Trump finds that additional steps must be taken to ensure meaningful accountability for perpetrators of war crimes, human rights violations and abuses, and the proliferation of narcotics trafficking networks in and in relation to Syria during the former regime of Bashar al-Assad and by those associated with it. Perpetrators of such actions threaten to undermine peace, security, and stability in the region, and thereby constitute an unusual and extraordinary threat to the national security and foreign policy of the United States.
- President Trump hereby expands the scope of the national emergency declared in Executive Order 13894 of October 14, 2019 (Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria), as amended in and relied on for additional steps taken in Executive Order 14142 of January 15, 2025 (Taking Additional Steps With Respect to the Situation in Syria), to deal with that threat, and accordingly further amend Executive Order 13894 by:
(i) striking section 1(a) and inserting, in lieu thereof, the following:
“Section 1. (a) All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in:
- any person determined by the Secretary of the Treasury, in consultation with the Secretary of State:
(A) to be responsible for or complicit in, or to have directly or indirectly engaged in, or attempted to engage in, any of the following in or in relation to Syria:
- actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria; or
- the commission of serious human rights abuse;
(B) to be a former government official of the former regime of Bashar al-Assad or a person who acted for or on behalf of such an official;
(C) to have engaged in, or attempted to engage in, activities or transactions that have materially contributed to, or pose a significant risk of materially contributing to, the illicit production and international illicit proliferation of captagon;
(D) to be responsible for or complicit in, to have directly or indirectly engaged in, or to be responsible for ordering, controlling, or otherwise directing, instances in which a United States national ((i) as defined in 8 U.S.C. 1101(a)(22) or 8 U.S.C. 1408, or (ii) a lawful permanent resident with significant ties to the United States) went missing in Syria during the former regime of Bashar al-Assad;
(E) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of:
(1) the former regime of Bashar al-Assad;
(2) any activity described in subsections (a)(i)(A)–(a)(i)(D) of this section; or
(3) any person whose property and interests in property are blocked pursuant to this order;
(F) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order; or
(G) to be an adult family member of a person designated under subsections (a)(i)(A)–(a)(i)(D) of this section.”; and
(ii) striking section 2(a) and inserting, in lieu thereof, the following:
“Sec. 2. (a) The Secretary of State, in consultation with the Secretary of the Treasury and other officials of the United States Government as appropriate, is hereby authorized to impose on a foreign person any of the sanctions described in subsections (b) and (c) of this section, upon determining that the person, on or after the date of this order:
- is responsible for or complicit in, has directly or indirectly engaged in, or attempted to engage in, or financed the obstruction, disruption, or prevention of efforts to promote a Syria that is stable, unified, and at peace with itself and its neighbors, including:
(A) the convening and conduct of a credible and inclusive Syrian-led constitutional process;
(B) the preparation for and conduct of supervised elections, pursuant to the new constitution, that are free and fair and to the highest international standards of transparency and accountability; or
(C) the development of a Syrian government that is representative and reflects the will of the Syrian people;
(ii) is an adult family member of a person designated under subsection (a)(i) of this section; or
(iii) is responsible for or complicit in, or has directly or indirectly engaged in, or attempted to engage in, the expropriation of property, including real property, for personal gain or political purposes in Syria.”
(b) President Trump additionally amends Executive Order 13606 of April 22, 2012 (Blocking the Property and Suspending Entry into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria Via Information Technology), by removing the following text from the preamble: “Executive Order 13338 of May 11, 2004, as modified in scope and relied upon for additional steps in subsequent Executive Orders” and replacing it with: “Executive Order 13894 of October 14, 2019, and relied upon for additional steps and further amended in subsequent Executive Orders.”
Sec. 5. Caesar Act. The Secretary of State, in consultation with the Secretary of the Treasury, shall examine whether the criteria set forth in section 7431(a) of the Caesar Act have been met, and on the basis of that examination may, pursuant to the Presidential Memorandum of March 31, 2020 (Delegation of Certain Functions and Authorities Under the National Defense Authorization Act for Fiscal Year 2020), suspend in whole or in part the imposition of sanctions otherwise required under the Caesar Act. If the Secretary of State determines to suspend in whole or in part the imposition of such sanctions, the Secretary of State, in consultation with the Secretary of the Treasury, shall provide the briefing to the appropriate congressional committees required by section 7431(b) of the Caesar Act within 30 days of such determination. Further, the Secretary of State, in consultation with the Secretary of the Treasury, shall continue to review the situation in Syria, and if the Secretary of State, in consultation with the Secretary of the Treasury, determines that the criteria set forth in section 7431(a) are no longer met, the Secretary of State shall reimpose sanctions.
Sec. 6. Syria Accountability Act. President Trump hereby determines pursuant to section 5(b) of the Syria Accountability Act that it is in the national security interest of the United States to waive the application of subsection (a)(1), with respect to items on the Commerce Control List (supp. No. 1 to 15 C.F.R. part 774) only, and subsection (a)(2)(A) of the Syria Accountability Act only. The Secretary of State shall submit to the appropriate congressional committees the report required under section 5(b) of that Act.
Sec. 7. CBW Act. (a) Pursuant to section 307(d)(1)(B) of the CBW Act, President Trump hereby determines and certify that there has been a fundamental change in the leadership and policies of the Government of the Syrian Arab Republic. Accordingly, President Trump hereby waives the following sanctions imposed on Syria for the prior use of chemical weapons under the former regime of Bashar al-Assad:
- the restriction on foreign assistance under section 307(a)(1) of the CBW Act;
(ii) the restriction on United States Government credit, credit guarantees, or other financial assistance under section 307(a)(4) of the CBW Act;
(iii) the restrictions on the export of national security-sensitive goods and technology under section 307(a)(5) of the CBW Act and on all other goods and technology under section 307(b)(2)(C) of the CBW Act; and
(iv) the restriction on United States banks from making any loan or providing any credit to the Government of Syria under section 307(b)(2)(B) of the CBW Act.
(b) The Secretary of State shall transmit this waiver determination and report as required by sections 307(d)(1)(B) and (d)(2) of the CBW Act to the appropriate congressional committees. This waiver shall be effective 20 days after it has been so transmitted.
Sec. 8. Counterterrorism Designations. (a) The Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, shall take all appropriate action with respect to the designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham and other aliases, as a Foreign Terrorist Organization under 8 U.S.C. 1189 and as a Specially Designated Global Terrorist under 50 U.S.C. 1702 and Executive Order 13224, as well as the designation of Abu Muhammad al Jawlani, commonly known as Ahmed al-Sharaa, as a Specially Designated Global Terrorist.
(b) The Secretary of State shall take all appropriate action to review the designation of Syria as a State Sponsor of Terrorism consistent with section 1754(c) of the National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232; 50 U.S.C. 4813(c)), section 40 of the Arms Export Control Act (Public Law 90-629, as amended; 22 U.S.C. 2780), and section 620A of the Foreign Assistance Act of 1961 (Public Law 87-195, as amended; 22 U.S.C. 2371).
Sec. 9. United Nations. The Secretary of State shall take appropriate steps to advance United States policy objectives at the United Nations to support a Syria that is stable and at peace and to support Syrian efforts to counter terrorism and comply with its responsibilities and obligations concerning weapons of mass destruction, including chemical and biological weapons. The Secretary of State is further directed to explore avenues at the United Nations to provide sanctions relief in support of these objectives.
Sec. 10. Implementation. The Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce, as appropriate, are hereby authorized to take such actions, including adopting rules and regulations, as may be necessary to implement this order. The Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce may, consistent with applicable law, redelegate any of these functions within their respective agencies. The Secretary of State, in consultation with the Secretary of the Treasury, the Secretary of Commerce, and the Secretary of Transportation, as appropriate, is authorized to exercise the functions and authorities conferred upon the President in section 5 of the Syria Accountability Act and to redelegate these functions and authorities consistent with applicable law. All agencies of the United States shall take all appropriate measures within their authority to implement this order, consistent with applicable law.
Sec. 11. General Provisions.
- Nothing in this order shall be construed to impair or otherwise affect:
(i) the authority granted by law to an executive department or agency, or the head thereof; or
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary,
administrative, or legislative proposals.
- This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
- This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
(d) The costs for publication of this order shall be borne by the Department of State.
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Department of State, Directorate of Defense Trade Controls (DDTC)
Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses
June 11, 2025: 90 Fed. Reg. 23097: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=7aaf6c0a970622900083b3b0f053af61 and
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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Determinations Regarding Use of Chemical Weapons by Sudan Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991
June 27, 2025: 90 Fed. Reg. 27750: Pursuant to sections 306(a), 307(a), and 307(d) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (22 U.S.C. 5604(a), 5605(a), and 5605(d)), on April 24, 2025 the Senior Official performing the functions of the Under Secretary for Arms Control and International Security determined that the Government of Sudan has used chemical or biological weapons in violation of international law or lethal chemical or biological weapons against its own nationals. As a result, the following sanctions were imposed:
- Foreign Assistance: Termination of assistance to Sudan under the Foreign Assistance Act of 1961, except for urgent humanitarian assistance and food or other agricultural commodities or products.
The Senior Official performing the functions of the Under Secretary for Arms Control and International Security has determined that it is essential to the national security interests of the United States to waive the application of this restriction.
- Arms Sales: Termination of (a) sales to Sudan under the Arms Export Control Act of any defense articles, defense services, or design and construction services, and (b) licenses for the export to Sudan of any item on the United States Munitions List.
The Senior Official performing the functions of the Under Secretary for Arms Control and International Security has determined that it is essential to the national security interests of the United States to partially waive the application this sanction to allow for case-by-case adjudication of licenses or other authorizations for defense articles and defense services for entities other than the Government of Sudan on a case-by-case basis for the purposes described pursuant to section 126.1(v) of the International Traffic in Arms Regulations (ITAR).
- Arms Sales Financing: Termination of all foreign military financing for Sudan under the Arms Export Control Act.
- Denial of United States Government Credit or Other Financial Assistance: Denial to Sudan of any credit, credit guarantees, or other financial assistance by any department, agency, or instrumentality of the United States Government, including the Export-Import Bank of the United States.
- Exports of National Security-Sensitive Goods and Technology: Prohibition on the export to Sudan of any goods or technology controlled for National Security (NS) reasons on the Commerce Control List (CCL) established under 50 U.S.C. 4813(a)(1).
The Senior Official performing the functions of the Under Secretary for Arms Control and International Security has determined that it is essential to the national security interests of the United States to waive the application of this sanction in order to allow the authorization of exports or re-exports of NS-controlled goods or technology to Sudan in accordance with the following policies:
License Exceptions: Exports and re-exports of NS-controlled goods or technology on the CCL may be authorized under License Exceptions GOV, ENC, BAG, TMP, RPL, TSU and ACE, as described in 15 CFR part 740.
Safety of Flight: Exports and re-exports of NS-controlled goods or technology may be authorized pursuant to new licenses when necessary for the safety of flight of civil fixed-wing passenger aviation, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
Deemed Exports/Re-Exports: Exports and re-exports of goods or technology may be authorized pursuant to new licenses for deemed exports and re-exports to Sudanese nationals, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
Wholly Owned U.S. and Other Foreign Subsidiaries: Exports and re-exports of NS controlled goods or technology may be authorized pursuant to new licenses for exports and re-exports to wholly-owned U.S. and other foreign subsidiaries in Sudan, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
These measures shall be implemented by the responsible departments and agencies of the United States government and will remain in place for at least one year and until further notice.
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DDTC Name And Address Changes Posted To Website
June 3 through June 13, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in Name of Jacobs Australia Pty Limited to Amentum Australia Proprietary Limited due to merger;
- Change in Address of FISBA, LLC from 983 Riverside Street, Portland, ME 04103 to 6 Willey Road, Saco, ME 04072;
- Change in Address of GE Aviation Systems North America LLC - Abu Dhabi from Al Hisn, East 6, C5, building Amna Ahmed Mohamed O, Abu Dhabi, United Arab Emirates to Al Hisn, East 6, C5, building Amna Ahmed Mohamed Onwani, 621, Zayet The First St., Al Hisn, Abu Dhabi 20035, United Arab Emirates;
- Change in Name of Centum Solutions S.L. to Bertrandt Technology Spain S.L. D due to acquisition.
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DDTC Frequently Asked Questions (FAQs)
Q: What does it mean to be on one of DDTC's lists of debarred parties?
A: Persons subject to statutory or administrative debarment are generally prohibited from participating directly or indirectly in ITAR-controlled activities, such as the export of technical data and other defense articles and the furnishing of defense services for which a license or other approval is required. Also, pursuant to ITAR § 127.1(d), it is a violation for a person with knowledge that another person is ineligible under ITAR § 120.16(c), which includes debarred parties, to, among other things, apply for, obtain, or use an export control document on behalf of a debarred party, or participate in a transaction subject to the ITAR that will benefit a debarred party, without first obtaining DDTC’s approval.
DDTC has specified the consequences of debarment in the ITAR, and the Federal Register Notices announcing the debarment provide further detail regarding the debarment. DDTC does not impose any restrictions on a debarred party’s eligibility to obtain banking services, engage in real estate transactions, purchase automobiles, or participate in any other activity not controlled under the ITAR.
Q: Where can I find or track the status of my registration?
A: Registrations submitted in DECCS can be tracked in the DECCS registration application on the Registration Dashboard page under the “In Progress” or “Active Registration” sections.
It normally takes 30 days on average from the time the registration application is submitted for DDTC to adjudicate your registration. Once the review has been completed and approved, the Registration Dashboard with be updated to show the new status of the registration application. Please refer to What are the Registration Status Definitions? (KB0011498) for details on the various Registration Status Codes.
Q: What is the benefit of citing precedent cases?
A: Citing relevant precedent cases assists the Licensing Officer in reviewing the proposed application by providing license and staffing history. It is requested that the cited precedent be for the same commodity and same end-use/end-user of the proposed application
Q: If I am a U.S. person providing a defense service to a foreign entity, do I need to register with DDTC?
A: That will depend upon whether you are permanently residing in the United States or abroad. Registration is not required if you both physically reside and provide the defense service outside the United States. Under ITAR § 122.1(a), registration is required only for persons who engage in the United States in the business of furnishing defense services or manufacturing, exporting, or temporarily importing defense articles. If at any point you engage in the United States in the business of furnishing defense services (to include remote work/telework), you would be required to register with the Department unless otherwise exempted from the registration requirement as described in ITAR § 122.1(b).
Q: DECCS says that my authorization has been approved but I have not yet received my authorization letter. What do I do?
A: Authorization letters are electronically sent to the to the applicant’s email address as provided in the application. If it has been more than a week since the case closed in DECCS, check your junk mail folder. Authorization letters will come from DDTCPaperCase@state.gov. If after checking your spam folder you find that you still have not received the authorization, email the USPAB Case Status Orgbox at PM-DTCL-USPAB-Status@state.gov.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To Kuwait
June 4, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Kuwait has requested to buy equipment and services related to sustainment support for legacy M1A2 and new M1A2K Abrams main battle tank systems. The following non-MDE items will be included: repair parts; spare parts; replacement materials; and other related elements of logistics and program support. The estimated total cost is $325 million. The principal contractor will be General Dynamics Land Systems, located in Sterling Heights, MI. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To The Netherlands
June 12, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Netherlands has requested to buy two hundred ninety-six (296) AGM-179A Joint Air-to-Ground Missiles (JAGM). The following non-MDE items will also be included: AGM-179 JAGM Captive Air Training Missiles (CATM); Tactical Aviation Ground Munition Program (TAGM) office technical assistance; Security Assistance Management Directorate (SAMD), Joint Attack Munition Systems (JAMS) technical assistance; missile handling training; classified and unclassified publications; spare parts; repair and return; storage; and other related elements of program and logistical support. The estimated total cost is $215 million. The principal contractor will be Lockheed Martin Corporation, located in Orlando, FL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Italy
June 16, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Italy has requested to buy thirty (30) AIM-120D-3 Advanced Medium-Range Air-to-Air Missiles (AMRAAM), forty (40) AIM-120C-8 AMRAAMs, and two (2) AIM-120C-7 AMRAAM guidance sections. The following non-MDE items will also be included: AMRAAM control section spares and containers; spare and repair parts, consumables, accessories, and repair and return support; weapon system support and software; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; U.S. government and contractor engineering, technical, and logistical support services; and other related elements of logistics and program support. The estimated total cost is $211 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Australia
June 16, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Australia has requested to buy the following equipment and services related to sustainment of its F/A-18F Super Hornet and EA-18G Growler aircraft fleet: sixty (60) Global Lightning – Joint Tactical Terminal – Transceivers (JTT-X); forty (40) Advanced Electronic Warfare systems; and twenty-four (24) Next Generation Electronic Attack Units (NGEAU). The following non-MDE items will also be included: AN/PYQ-10C Simple Key Loaders; Inline Network Encryptors; AN/ALE-47 electronic warfare countermeasures systems (common carriage); Joint Mission Planning System (JMPS) software; aircraft spares and repair parts; other support equipment; software and hardware updates and development; system configuration upgrades; avionics software support; aircraft armament equipment; Foreign Liaison Officer support; technical data; engineering change proposals; engine component improvements; training and training equipment; training aids, devices, and spares; flight test services; transportation costs; system integration and testing; software development and integration; tools and test equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $2.0 billion. The principal contractor will be The Boeing Company, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Israel
June 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Israel has requested to buy three thousand eight hundred forty-five (3,845) KMU-558B/B Joint Direct Attack Munition (JDAM) guidance kits for the BLU-109 bomb body and three thousand two hundred eighty (3,280) KMU-572 F/B JDAM guidance kits for the MK 82 bomb body. The following non-MDE items will also be included: U.S. government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $510 million. The principal contractor will be The Boeing Company, located in St. Charles, MO. Part of the JDAM guidance kit requirement may be transferred from U.S. government stock. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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U.S. Census Bureau
How to Resolve Common AES Response Messages
June 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: 504
Narrative: License Code Unknown
Severity: Fatal
Reason: The License Code reported is not valid in AES.
Resolution: The License Code/License Exemption Code must be reported on each EEI. Valid License Codes reportable in AES can be found in Appendix F – License and License Exemption Type Codes and Reporting Guidelines.
Verify the License Code/License Exemption Code, correct the shipment and resubmit.
For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.
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Alcohol and Tobacco Tax and Trade Bureau (TTB) removed from the Automated Export System Trade Interface Requirements (AESTIR)
June 25, 2025:
CSMS # 65439382 - Alcohol and Tobacco Tax and Trade Bureau (TTB) removed from the Automated Export System Trade Interface Requirements (AESTIR)
The Alcohol and Tobacco Tax and Trade Bureau (TTB) has inactivated its Partner Government Agency (PGA) Export Message Set. References for TTB have been removed from Appendices Q and X of the Automated Export System Trade Interface Requirement (AESTIR). Previously, the submission of TTB PGA export message set had been voluntary. TTB discontinued collection of this data as a deregulatory action.
Referenced appendices can be viewed here: https://www.cbp.gov/trade/aes/aestir/appendices
| LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
Department of Commerce – Bureau of Industry and Security (BIS)
June 9, 2025: A 22-count indictment was unsealed charging Iurii Gugnin, also known as Iurii Mashukov and George Goognin, 38, a resident of New York and citizen of Russia, with various offenses related to using his cryptocurrency company Evita to funnel more than $500 million of overseas payments through U.S. banks and cryptocurrency exchanges while hiding the source and purpose of the transactions.
According to court documents, Gugnin is charged with wire and bank fraud, conspiracy to defraud the United States, violation of the International Emergency Economic Powers Act (IEEPA), operating an unlicensed money transmitting business, failing to implement an effective anti-money laundering compliance program, failing to file suspicious activity reports, money laundering, and related conspiracy charges. Gugnin was arrested and arraigned in New York.
If convicted, Gugnin faces a maximum penalty of 30 years in prison for each count of bank fraud; a maximum penalty of 20 years in prison for each of the wire fraud, IEEPA, money laundering, and related conspiracy counts; a maximum penalty of 10 years in prison for failure to implement an effective anti-money laundering program and failure to file suspicious activity reports; and a maximum penalty of five years in prison for conspiracy to defraud the United States and operating an unlicensed money transmitting business.
https://media.bis.gov/news-updates
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June 10, 2025: An illegal alien from China pleaded guilty to federal criminal charges for illegally exporting firearms, ammunition and other military items to North Korea by concealing them inside shipping containers that departed from the Port of Long Beach, California, and for committing this crime at the direction of North Korean government officials, who wired him approximately $2 million for his efforts.
Shenghua Wen, 42, of Ontario, California, pleaded guilty to one count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA) and one count of acting as an illegal agent of a foreign government. Wen has been in federal custody since his arrest in December 2024.
Wen faces a maximum penalty of 20 years in prison on the count of violating the IEEPA and a maximum penalty of 10 years in prison on the count of acting as an illegal agent of a foreign government. Sentencing is scheduled for Aug. 18. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.
https://media.bis.gov/news-updates
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June 23, 2025: The Bureau of Industry and Security, U.S. Department of Commerce (“BIS”), has notified Unicat Catalyst Technologies, LLC, of Alvin, Texas, as successor to Unicat Catalyst Technologies, Inc., (“Unicat”), of its intention to initiate an administrative proceeding against Unicat pursuant to Section 766.3 of the Export Administration Regulations (the “Regulations”), through the issuance of a Proposed Charging Letter to Unicat that alleges that Unicat committed three violations of the Regulations.
Specifically: On three occasions between on or about October 2017 through on or about September 2020, Unicat Catalyst Technologies, Inc. (“Legacy Unicat”), which was acquired by a private equity firm and converted into the successor entity Unicat, engaged in conduct prohibited by the Regulations when it sold and arranged for the export of items subject to the EAR and designated EAR99, specifically, catalysts, valued at $391,182.78, with knowledge that these items were intended for export to Iran without the requisite license or other authorization. By arranging for the export of the items without the required license or other authorization, Legacy Unicat committed three violations of Section 764.2(e) of the Regulations.
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Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
June 5, 2025: The United States sanctioned four individuals, currently serving as judges of the International Criminal Court (ICC). It reflects the seriousness of the threat we face from the ICC’s politicization and abuse of power. The Department of State’s designations are made pursuant to Executive Order (E.O.) 14203, which authorizes sanctions on foreign persons engaged in certain efforts by the ICC and aims to impose tangible and significant consequences on those directly engaged in the ICC’s transgressions against the United States and Israel.
The following individuals have been added to OFAC’s SDN List:
- Alapini Gansou, Reine Adelaide Sophie of the Netherlands;
- Bossa, Solomy Balungi of the Netherlands;
- Hohler, Beti of the Netherlands; and
- Ibanez Carranza, Luz Del Carmen of the Netherlands.
The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued ICC-related General License 1, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on June 5, 2025," ICC-related General License 2, "Authorizing the Provision of Certain Legal Services;" ICC-related General License 3, "Authorizing Payments for Legal Services From Funds Originating Outside the United States;" ICC-related General License 4, "Authorizing Emergency Medical Services;" ICC-related General License 5, "Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized;" ICC-related General License 6, "Authorizing Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Personal, Non-Commercial Use;" and ICC-related General License 7, "Official Business of the United States Government."
GENERAL LICENSE NO. 1: “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on June 5, 2025”
(a) All transactions prohibited by Executive Order (E.O.) 14203 that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern daylight time, July 8, 2025, provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States:
(1) Solomy Balungi Bossa;
(2) Luz Del Carmen Ibanez Carranza;
(3) Reine Adelaide Sophie Alapini Gansou;
(4) Beti Hohler; or
(5) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
GENERAL LICENSE NO. 2: “Authorizing the Provision of Certain Legal Services”
(a) The provision of the following legal services to or on behalf of persons whose property and interests in property are blocked pursuant to Executive Order (E.O.) 14203 is authorized, provided that any receipt of payment of professional fees and reimbursement of incurred expenses must be authorized pursuant to General License 3 under E.O. 14203, which authorizes certain payments for legal services from funds originating outside the United States; via specific license; or otherwise pursuant to E.O. 14203:
(1) Provision of legal advice and counseling on the requirements of and compliance with the laws of the United States or any jurisdiction within the United States, provided that such advice and counseling are not provided to facilitate transactions in violation of E.O. 14023;
(2) Representation of persons named as defendants in or otherwise made parties to legal, arbitration, or administrative proceedings before any U.S. federal, state, or local court or agency;
(3) Initiation and conduct of legal, arbitration, or administrative proceedings before any U.S. federal, state, or local court or agency;
(4) Representation of persons before any U.S. federal, state, or local court or agency with respect to the imposition, administration, or enforcement of U.S. sanctions against such persons; and
(5) Provision of legal services in any other context in which prevailing U.S. law requires access to legal counsel at public expense.
(b) The provision of any other legal services to or on behalf of persons whose property and interests in property are blocked pursuant to E.O. 14203, not otherwise authorized pursuant to a general license issued pursuant to E.O. 14203, requires the issuance of a specific license.
(c) U.S. persons do not need to obtain specific authorization to provide related services, such as making filings and providing other administrative services, that are ordinarily incident to the provision of services authorized by paragraph (a) of this general license. Additionally, U.S. persons who provide services authorized by paragraph (a) of this general license do not need to obtain specific authorization to contract for related services that are ordinarily incident to the provision of those legal services, such as those provided by private investigators or expert witnesses, or to pay for such services.
(d) Entry into a settlement agreement or the enforcement of any lien, judgment, arbitral award, decree, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to E.O. 14203 is prohibited unless licensed pursuant to E.O. 14203.
GENERAL LICENSE NO. 3: “Authorizing Payments for Legal Services From Funds Originating Outside the United States”
(a)(1) Professional fees and incurred expenses. Receipt of payment of professional fees and reimbursement of incurred expenses for the provision of legal services authorized pursuant to General License 2 under Executive Order (E.O.) 14203 to or on behalf of any person whose property and interests in property are blocked pursuant to E.O. 14203 is authorized from funds originating outside the United States, provided that the funds do not originate from:
(i) A source within the United States;
(ii) Any source, wherever located, within the possession or control of a U.S. person; or
(iii) Any individual or entity, other than the person on whose behalf the legal services authorized pursuant to General License 2 under E.O. 14203 are to be provided, whose property and interests in property are blocked pursuant to E.O. 14203, any part of 31 CFR chapter V, or any other Executive order or statute.
(2) Nothing in paragraph (a) authorizes payments for legal services using funds in which any other person whose property and interests in property are blocked pursuant to E.O. 14203, any part of 31 CFR chapter V, or any other Executive order or statute has an interest.
(b) Records. U.S. persons who receive payments pursuant to paragraph (a) of this general license must retain for 10 years from the date of the relevant payment, and furnish to OFAC on demand, a record that specifies the following for each payment:
(1) The individual or entity from whom the funds originated and the amount of funds received; and (2) If applicable:
(i) The names of any individuals or entities providing related services to the U.S. person receiving payment in connection with authorized legal services, such as private investigators or expert witnesses;
(ii) A general description of the services provided; and
(iii) The amount of funds paid in connection with such services
GENERAL LICENSE NO. 4: “Authorizing Emergency Medical Services”
The provision and receipt of nonscheduled emergency medical services that are prohibited by Executive Order 14203 are authorized.
GENERAL LICENSE NO. 5: “Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized”
(a) A U.S. financial institution is authorized to debit any account blocked pursuant to Executive Order (E.O.) 14203 held at that financial institution in payment or reimbursement for normal service charges owed it by the owner of that blocked account.
Note to paragraph (a). As used in this general license, the term normal service charges shall include charges in payment or reimbursement for interest due; cable, telegraph, internet, or telephone charges; postage costs; custody fees; small adjustment charges to correct bookkeeping errors; and, but not by way of limitation, minimum balance charges, notary and protest fees, and charges for reference books, photocopies, credit reports, transcripts of statements, registered mail, insurance, stationery and supplies, and other similar items.
(b) Any payment of funds or transfer of credit in which a person whose property and interests in property are blocked pursuant to E.O. 14203 has any interest that comes within the possession or control of a U.S. financial institution must be blocked in an account on the books of that financial institution. A transfer of funds or credit by a U.S. financial institution between blocked accounts in its branches or offices is authorized, provided that no transfer is made from an account within the United States to an account held outside the United States, and further provided that a transfer from a blocked account may be made only to another blocked account held in the same name.
Note to paragraph (b). Such transfers must be reported to the Office of Foreign Assets Control consistent with § 501.603 of the Reporting, Procedures and Penalties Regulations, 31 CFR part 501.
GENERAL LICENSE NO. 6: “Authorizing Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Personal, Non-Commercial Use”
(a) All transactions prohibited by Executive Order (E.O.) 14203 that are related to the provision, directly or indirectly, of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to an individual whose property and interests in property are blocked pursuant to E.O. 14203 are authorized, provided the items are in quantities consistent with personal, non-commercial use.
(b) For the purposes of this general license, agricultural commodities, medicine, and medical devices are defined as follows:
(1) Agricultural commodities. For the purposes of this general license, agricultural commodities are:
- Products that fall within the term “agricultural commodity” as defined in section 102 of the Agricultural Trade Act of 1978 (7 U.S.C. 5602); and (
- ii) That are intended for ultimate use as:
(A) Food for humans (including raw, processed, and packaged foods; live animals; vitamins and minerals; food additives or supplements; and bottled drinking water) or animals (including animal feeds);
(B) Seeds for food crops;
(C) Fertilizers or organic fertilizers; or
(D) Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food animals.
(2) Medicine. For the purposes of this general license, medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).
(3) Medical devices. For the purposes of this general license, a medical device is an item that falls within the definition of “device” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).
Note 1 to General License 6. This general license does not relieve any person authorized thereunder from complying with any other applicable laws or regulations
GENERAL LICENSE NO. 7: “Official Business of the United States Government”
All transactions prohibited by Executive Order (E.O.) 14203 that are for the conduct of the official business of the United States Government by employees, grantees, or contractors thereof are authorized.
Note to General License No. 7. See also section 7 of E.O. 14203, which exempts transactions for the conduct of the official business of the Federal Government by employees, grantees, or contractors thereof.
https://ofac.treasury.gov/recent-actions/20250605
https://ofac.treasury.gov/media/934326/download?inline
https://ofac.treasury.gov/media/934331/download?inline
https://ofac.treasury.gov/media/934336/download?inline
https://ofac.treasury.gov/media/934341/download?inline
https://ofac.treasury.gov/media/934346/download?inline
https://ofac.treasury.gov/media/934351/download?inline and
https://ofac.treasury.gov/media/934356/download?inline
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June 5, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four Guyanese nationals and two Colombian nationals responsible for trafficking tons of cocaine from South America to the United States, Europe, and the Caribbean. These sanctions target drug traffickers utilizing boats and narco-subs to traffic ton-quantities of cocaine, along with an alleged corrupt Guyanese law enforcement official. The sanctions also target individuals that are operating covert airstrips to traffic drugs via aircraft. For decades, reported corrupt actors have used Guyana as a transshipment point for the movement of drugs from South America to the United States, with Mexican drug cartels also maintaining a presence in the region. International cocaine trafficking remains a serious threat to the United States, as the substantial profits generated from these sales continue to fund and strengthen cartel operations.
The following individuals have been added to OFAC’s SDN List:
- Cromwell, Mark of Guyana;
- Daby Jr., Paul of Guyana;
- Duncan, Randolph of Guyana;
- Salazar Gutierrez, Manuel of Colombia;
- Sanchez Vallejo, Yeison Andres of Colombia; and
- Sawh, Himnauth of Guyana.
https://ofac.treasury.gov/recent-actions/20250605
https://home.treasury.gov/news/press-releases/sb0156 and
https://ofac.treasury.gov/media/934316/download?inline=
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June 6, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated over 30 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, who have collectively laundered billions of dollars through the international financial system via Iranian exchange houses and foreign front companies under their control as part of Iran’s “shadow banking” network. The regime leverages this network to evade sanctions and move money from its oil and petrochemical sales, which help the regime fund its nuclear and missile programs and support its terrorist proxies.
The following individuals have been added to OFAC’s SDN List:
- Kuhi, Fatemah Sarlak of Iran;
- Meshkat, Farahnaz of Iran;
- Shetaban, Hossein of Iran;
- Soltanizadeh, Parviz of Iran;
- Zarringhalam, Fazlolah of Iran;
- Zarringhalam, Mansour of Iran;
- Zarringhalam, Mitra of Iran;
- Zarringhalam, Nasser of Iran;
- Zarringhalam, Pouria of Iran; and
- Zhang, Yu of China.
The following entities have been added to OFAC’s SDN List:
- Ace Petrochem Fze of the United Arab Emirates;
- Bstsheh HK Limited of China;
- Chungling HK Limited of China;
- Fitage Limited of China;
- Golden Pen General Trading L.L.C. of the United Arab Emirates;
- Gutown Trade Limited of China;
- Hero Companion Limited of China;
- S Serenity Trading FZE of the United Arab Emirates;
- Kimia Sadr Pasargad Company of Iran;
- Kinlere Trading Limited of China;
- Konosag Trading Limited of China;
- Lastsix Trading Limited of China;
- Magical Eagle Limited of China;
- Mansour Zarrin Ghalam and Partners Company of Iran;
- Marlena Trading Limited of China;
- Moderate General Trading L.L.C. of the United Arab Emirates;
- Nasser Zarrin Ghalam and Partners Company of Iran;
- Plzcome Limited of China;
- Prettyandy Trading Limited of China;
- Profu Company Limited of China;
- Questano HK Limited of China;
- Saldiege Trading Limited of China;
- Wide Vision General Trading L.L.C. of China;
- Xia Trading Limited of China;
- Yiminai Autoparts Trading Limited of China;
- Zarrin Ghalam and Partners Company of Iran; and
- Zarrin Tehran Investment Company of Iran.
https://home.treasury.gov/news/press-releases/sb0159
https://ofac.treasury.gov/recent-actions/20250606
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June 9, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Los Chapitos, a powerful faction of the Mexico-based Sinaloa Cartel that facilitates illicit fentanyl trafficking and production. Los Chapitos-controlled laboratories are responsible for introducing fentanyl in counterfeit pills manufactured by the Sinaloa Cartel and trafficked to the United States. Gunmen linked to the Sinaloa Cartel were also involved in the October 18, 2024 killing of former U.S. Marine Nicholas Quets in Sonora, Mexico.
The following individuals have been added to OFAC’s SDN List:
- Barraza Pablos, Victor Manuel of Mexico;
- Nunez Rios, Jose Raul of Mexico; and
- Urias Vazquez, Sheila Paola of Mexico.
The following entities have been added to OFAC’s SDN List:
- Beach y Marina, S.A. DE C.V. of Mexico;
- Carpe Diem Spa of Mexico;
- Club Playa Real, S.A. DE C.V. of Mexico;
- Comercializadora Copado, S.A. DE C.V. of Mexico;
- Eco Campestres Ultra, S.A.P.I. of Mexico;
- IMB 24 Siete, S.A. DE C.V of Mexico;
- Los Chapitos of Mexico;
- Mkt 24 Siete, S.A. DE C.V of Mexico;
- Mue Renta y Venta De Vestidos of Mexico;
- Poyecta Interna, S.A. DE C.V. of Mexico; and
- Sea WA Beach Club, S.A. DE C.V. of Mexico.
https://home.treasury.gov/news/press-releases/sb0161 and
https://ofac.treasury.gov/recent-actions/20250609
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June 10, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five individuals, and five sham charities located abroad that are prominent financial supporters of Hamas’s Military Wing and its terrorist activities. The individuals and entities sanctioned are responsible for funding Hamas’s Military Wing under the pretense of conducting humanitarian work, both internationally and in Gaza. Treasury also targeted a separate fraudulent charity linked to the Popular Front for the Liberation of Palestine (PFLP).
The following individuals have been added to OFAC’s SDN List:
- Abu Marei, Muhammad Sami Muhammad of Palestine;
- Abu Rashed, Amin of the Netherlands;
- Arawi, Zeki Abduallah Ibrahim of Turkey;
- Brahimi, Ahmed of Algeria; and
- Rashed, Israa Abou of the Netherlands.
The following entities have been added to OFAC’s SDN List:
- Addammer Prisoner Support and Human Rights Association of Israel;
- Al Weam Charitable Society of Northern Gaza;
- Associazone Benefica La Cupola D’oro of Italy;
- El Baraka Association For Charitable and Humanitarian Work of Algeria;
- Filistin Vakfi of Turkey; and
- Israa Charitable Foundation Netherlands of the Netherlands.
https://ofac.treasury.gov/recent-actions/20250610
https://home.treasury.gov/news/press-releases/sb0162
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June 12, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has assessed a $215,988,868 civil monetary penalty against GVA Capital Ltd. of San Francisco, California for violations of OFAC's sanctions against Russia and for related reporting obligations. GVA Capital knowingly managed an investment for sanctioned Russian oligarch Suleiman Kerimov while aware of his blocked status. GVA Capital also failed to comply with an OFAC subpoena during OFAC's investigation into this matter.
The penalty amount reflects OFAC's determination that GVA Capital's conduct was egregious and not voluntarily self-disclosed.
https://ofac.treasury.gov/recent-actions/20250612
https://ofac.treasury.gov/media/934366/download?inline
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June 12, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) made the following additions to its SDN list.
The following individuals have been added to OFAC’s SDN List:
- Huthele, Nasr Mohsen Ali of Iraq.
The following entity has been added to OFAC’s SDN List:
- Kata’ib Al-Imam Ali of Iraq.
https://ofac.treasury.gov/recent-actions/20250612
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June 16, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $3,882,797 settlement with Unicat Catalyst Technologies, LLC (“Unicat”). Unicat, an Alvin, Texas-based company that sells catalyst products, has agreed to settle its potential civil liability for 13 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), and one apparent violation of the Venezuela Sanctions Regulations (VSR) that arose from its provision of catalyst products and consulting services to Iran and its sale of catalysts to a blocked Venezuelan entity. The settlement amount reflects OFAC’s determination that Unicat’s conduct was voluntarily self-disclosed and constituted an egregious case.
https://ofac.treasury.gov/media/934376/download?inline and
https://ofac.treasury.gov/media/934381/download?inline
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June 18, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five Mexico-based leaders of Cartel de Jalisco Nueva Generacion (CJNG). CJNG is a brutally violent cartel responsible for a significant share of fentanyl and other illicit drugs entering the United States. It uses murder as a tactic to intimidate rivals, including sending messages to other cartels through the targeted killings of women. The recent discovery of a CJNG recruitment camp, Izaguirre ranch—which was reportedly used to execute recruits that defy instructions—underscores the cartel’s brutal methods.
The following individual has been added to OFAC’s SDN List:
- Ruiz Velasco, Ricardo of Mexico.
https://ofac.treasury.gov/recent-actions/20250618
https://home.treasury.gov/news/press-releases/sb0169
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June 20, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela General License 5S – Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After December 20, 2025.
GENERAL LICENSE NO. 5S: “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After December 20, 2025”
- On or after December 20, 2025, all transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond that would be prohibited by subsection l(a)(iii) of Executive Order (E.O.) 13835 of May 21, 2018, as amended by E.O. 13857 of January 25, 2019, and incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized.
https://ofac.treasury.gov/media/934391/download?inline
https://ofac.treasury.gov/media/934391/download?inline
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June 20, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took its single largest action to date against Iran-backed Ansarallah, commonly known as the Houthis, targeting four individuals, 12 entities, and two vessels that have imported oil and other illicit goods in support of the terrorist group. This action includes Houthi front companies, their owners, and other key Houthi operatives that generate significant revenue for the group through the sale of oil and other commodities on Yemen’s black market and by engaging in smuggling operations through Houthi-controlled ports. As part of this action, Treasury is also targeting two vessels, as well as their owners and operators, which violated U.S. sanctions by discharging oil derivatives to the Houthis.
The following individuals have been added to OFAC’s SDN List:
- Al-Washli, Zaid of Yemen;
- Dabbash, Abdullah Ahsan Abdullah of Yemen;
- Daghsan, Daghsan Ahmed of Yemen; and
- Talea, Ali Ahmed Daghsan of Yemen.
The following entities have been added to OFAC’s SDN List:
- Abbot Trading Co., Ltd. of Yemen;
- Atlantis M. Shipping Co of the Marshall Islands:
- Azzahra Establishment for Commerce and Agencies of Yemen;
- Best Way Tanker Corp of Moldova;
- Black Diamond Petroleum Derivatives of Yemen;
- Gasoline Aman Company For Oil Derivatives Imports of Yemen;
- Ocean Voyage LLC of Azerbaijan;
- Royal Plus Shipping Services and Commercial Agencies of Yemen;
- Star Plus Yemen Trading Limited of Yemen;
- Tamco Establishment for Oil Derivatives of Yemen;
- Yahya Al-Usalli Company for Import Limited of Yemen; and
- Yemen Elaph Petroleum Derivatives Import of Yemen.
The following vessels have been added to OFAC’s SDN List:
- Atlantis MZ (D604003) Crude Oil Tanker Unknown flag; Former Vessel Flag Comoros; MMSI 620800003 (vessel); and
- Valente (T8A4170) Crude Oil Tanker Palau flag; MMSI 511100949 (vessel).
https://ofac.treasury.gov/recent-actions/20250620 and
https://home.treasury.gov/news/press-releases/sb0174
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June 20, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated one individual and eight entities, and identifying one vessel as blocked property, for their involvement in the procurement and transshipment of sensitive machinery for Iran’s defense industry. The vessel, SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd, was carrying this machinery for OFAC-designated Rayan Roshd Afzar Company (RRA) and Towse Sanaye Nim Resanaye Tarashe, a company controlled by RRA executives. This action is being taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied the development of missiles and other weapons capabilities and that the Islamic Revolutionary Guard Corps (IRGC) and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities.
The following individual has been added to OFAC’s SDN List:
- Zhang, Yanbing of China.
The following entities have been added to OFAC’s SDN List:
- Athena Shipping Co Ltd of China;
- Dongguan Zanyin Machinery and Equipment Co Ltd of China;
- Edisa Dis Ticaret Limited Sirketi of Turkey;
- Futech Co Ltd of China;
- Shenzhen Xinxin Shipping Co Ltd of China;
- Towse Sanaye Nim Resanaye Tarashe of Iran;
- Unico Shipping Co Ltd of China; and
- V-shipping Pte Ltd of Singapore.
The following vessel has been added to OFAC’s SDN List:
- Shun Kai Xing (3E5884) Bulk Carrier Panama flag; MMSI 352003792 (vessel)
https://ofac.treasury.gov/recent-actions/20250620 and
https://home.treasury.gov/news/press-releases/sb0175
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June 24, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Giovanni Vicente Mosquera Serrano (Mosquera Serrano), a fugitive leader of Tren de Aragua (TdA) who is involved in the organization’s drug trafficking and financial operations. TdA is a Foreign Terrorist Organization (FTO) of Venezuelan origin that has launched a campaign of terror throughout the Western Hemisphere, including in the United States, and continues to expand. TdA is involved in illicit drug trade, human smuggling and trafficking, extortion, sexual exploitation of women and children, and money laundering, among other criminal activities.
The following individual has been added to OFAC’s DN List:
- Mosquera Serrano, Giovanni Vicente of Venezuela.
https://home.treasury.gov/news/press-releases/sb0178 and
https://ofac.treasury.gov/recent-actions/20250624
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June 27, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 115B, "Authorizing Certain Transactions Related to Civil Nuclear Energy."
In addition, OFAC invites the general public and other Federal agencies to comment on a proposed information collection, as required by the Paperwork Reduction Act of 1995. OFAC is soliciting comments concerning a proposal to add an electronic Sanctions Reconsideration Portal information collection within OFAC’s Reporting, Procedures and Penalties Regulations. This notice is currently available with the Federal Register. Written comments must be received by August 25, 2025, to be assured of consideration.
GENERAL LICENSE NO. 115B: “Authorizing Certain Transactions Related to Civil Nuclear Energy”
(a) All transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to civil nuclear energy are authorized through 12:01 a.m. eastern standard time, December 19, 2025:
(1) Gazprombank Joint Stock Company;
(2) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
(3) Public Joint Stock Company Bank Financial Corporation Otkritie;
(4) Sovcombank Open Joint Stock Company;
(5) Public Joint Stock Company Sberbank of Russia;
(6) VTB Bank Public Joint Stock Company;
(7) Joint Stock Company Alfa-Bank;
(8) Public Joint Stock Company Rosbank;
(9) Bank Zenit Public Joint Stock Company;
(10) Bank Saint-Petersburg Public Joint Stock Company;
(11) National Clearing Center (NCC);
(12) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or
(13) the Central Bank of the Russian Federation.
(b)For the purposes of this general license, the term “related to civil nuclear energy” means transactions undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024.
Additionally, OFAC has updated several Russia-related Frequently Asked Questions (FAQ 966, FAQ 967, FAQ 978, FAQ 999, FAQ 1010, FAQ 1011, FAQ 1117, FAQ 1182, FAQ 1203, and FAQ 1216).
https://ofac.treasury.gov/media/934396/download?inline
https://ofac.treasury.gov/recent-actions/20250627
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June 30, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action to implement the President’s Executive Order (E.O.) of June 30, 2025, “Providing for the Revocation of Syria Sanctions,” removing U.S. sanctions on Syria in support of the Syrian people and their new government as they rebuild their country and have the opportunity to become a stable and prosperous nation at peace with itself and its neighbors. This E.O. revokes the Executive orders that previously placed comprehensive sanctions on Syria. The E.O. also ensures continued accountability for the Bashar al-Assad regime, expanding the national emergency declared in E.O. 13894 to allow for the continuation of sanctions against Bashar al-Assad, his associates, and other destabilizing regional actors.
On June 30, the President issued an Executive Order "Providing for the Revocation of Syria Sanctions" that removes U.S. sanctions on Syria, effective July 1, 2025. To implement the President's action, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued four new Syria Frequently Asked Questions (FAQs 1220-1223).
FAQ 1220:
Q: How does the Executive Order (E.O.) of June 30, 2025, "Providing for the Revocation of Syria Sanctions," affect OFAC's Syria Sanctions Program?
A: The E.O. of June 30, 2025 removes sanctions on Syria, effective July 1, 2025, while maintaining sanctions on Bashar al-Assad and certain other destabilizing regional actors. Specifically, the E.O. revokes the following six E.O.s that form the foundation of the Syrian Sanctions Program and terminates the national emergency underlying those E.O.s, effective July 1, 2025:
- E.O. 13338 of May 11, 2004;
- E.O. 13399 of April 25, 2006;
- E.O. 13460 of February 13, 2008;
- E.O. 13572 of April 29, 2011;
- E.O. 13573 of May 18, 2011; and
- E.O. 13582 of August 17, 2011.
As a result, as of July 1, 2025, the economic sanctions administered by OFAC that constitute the Syria Sanctions Program are no longer in effect. Persons blocked solely pursuant to these above E.O.s were removed from OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List), and all property and interests in property of such persons are unblocked. OFAC will remove the Syrian Sanctions Regulations from the Code of Federal Regulations. Pending or future OFAC investigations or enforcement actions related to apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025 may still be carried out.
Additionally, the E.O. of June 30, 2025 also preserves and expands OFAC's ability to target Bashar al-Assad and his associates, human rights abusers, captagon drug traffickers, and other destabilizing regional actors by further amending E.O. 13894. Concurrently with the issuance of the E.O. of June 30, 2025, OFAC designated 139 persons who were previously designated under the Syrian Sanctions Program under E.O. 13894, as further amended, or other OFAC authorities.
FAQ 1221:
Q: Can U.S. financial institutions establish relationships with Syrian financial institutions, including the Central Bank of Syria?
A: Yes. All Syrian financial institutions, including the Central Bank of Syria, have been removed from OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List).
Effective July 1, 2025, U.S. persons are not prohibited from providing financial services to Syria, processing payments on behalf of third country financial institutions involving Syrian financial institutions, or conducting transactions with the new Government of Syria and Syrian financial institutions, provided that none of the involved parties are on the SDN List. This includes establishing correspondent banking relationships with Syrian financial institutions. In line with the lifting of Syria sanctions, the Financial Crimes Enforcement Network issued exceptive relief in late May 2025 to permit U.S. financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria. OFAC strongly encourages financial institutions to employ a risk-based sanctions compliance program and update it as appropriate in consideration of new business lines.
FAQ 1222:
Q: Do I need a specific license from OFAC to export or reexport food or medicine to Syria?
A: No. The United States no longer maintains comprehensive sanctions on Syria, effective July 1, 2025, following the issuance of the E.O. of June 30, 2025. You may send U.S.-origin food or medicine to Syria without a specific license from OFAC.
Furthermore, the Department of Commerce maintains jurisdiction over the export of most items to Syria. In the E.O. of June 30, 2025, the President waived requirements to impose certain export controls under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. Please refer to the Department of Commerce for more specifics on export controls involving Syria.
FAQ 1223:
Q: Can persons continue to rely on Syria General License (GL) 25 after the revocation of the Syrian Sanctions Program, on July 1, 2025?
A: Yes. While Syria GL 25 authorizes transactions otherwise prohibited under the Syrian Sanctions Regulations, it also authorizes transactions involving specified persons otherwise prohibited by certain other sanctions programs. To the extent necessary, persons may continue to rely on GL 25 and the related Frequently Asked Questions (FAQs).
https://home.treasury.gov/news/press-releases/sb0183 and
https://ofac.treasury.gov/recent-actions/20250630
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The Department of the Treasury's Office of Foreign Assets Control (OFAC) published regulations to implement Executive Order 14203 of February 26, 2025, "Imposing Sanctions on the International Criminal Court ." These regulations are currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on July 1, 2025.
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