This newsletter is a listing of the latest changes in export control regulations through July 31, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
We have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
PROMOTING THE EXPORT OF THE AMERICAN AI TECHNOLOGY STACK
July 23, 2025: By the authority vested in the President by the Constitution and the laws of the United States of America, including section 301 of title 3, United States Code, it is hereby ordered:
Section 1. Purpose. Artificial intelligence (AI) is a foundational technology that will define the future of economic growth, national security, and global competitiveness for decades to come. The United States must not only lead in developing general-purpose and frontier AI capabilities, but also ensure that American AI technologies, standards, and governance models are adopted worldwide to strengthen relationships with our allies and secure our continued technological dominance. This order establishes a coordinated national effort to support the American AI industry by promoting the export of full-stack American AI technology packages.
Sec. 2. Policy. It is the policy of the United States to preserve and extend American leadership in AI and decrease international dependence on AI technologies developed by our adversaries by supporting the global deployment of United States-origin AI technologies.
Sec. 3. Establishment of the American AI Exports Program. (a) Within 90 days of the date of this order, the Secretary of Commerce shall, in consultation with the Secretary of State and the Director of the Office of Science and Technology Policy (OSTP), establish and implement the American AI Exports Program (Program) to support the development and deployment of United States full-stack AI export packages.
(b) The Secretary of Commerce shall issue a public call for proposals from industry-led consortia for inclusion in the Program. The public call shall require that each proposal must:
(i) include a full-stack AI technology package, which encompasses:
(A) AI-optimized computer hardware (e.g., chips, servers, and accelerators), data center storage, cloud services, and networking, as well as a description of whether and to what extent such items are manufactured in the United States;
(B) data pipelines and labeling systems;
(C) AI models and systems;
(D) measures to ensure the security and cybersecurity of AI models and systems; and
(E) AI applications for specific use cases (e.g., software engineering, education, healthcare, agriculture, or transportation);
(ii) identify specific target countries or regional blocs for export engagement;
(iii) describe a business and operational model to explain, at a high level, which entities will build, own, and operate data centers and associated infrastructure;
(iv) detail requested Federal incentives and support mechanisms; and
(v) comply with all relevant United States export control regimes, outbound investment regulations, and end-user policies, including chapter 58 of title 50, United States Code, and relevant guidance from the Bureau of Industry and Security within the Department of Commerce.
(c) The Department of Commerce shall require proposals to be submitted no later than 90 days after the public call for proposals is issued, and shall consider proposals on a rolling basis for inclusion in the Program.
(d) The Secretary of Commerce shall, in consultation with the Secretary of State, the Secretary of Defense, the Secretary of Energy, and the Director of OSTP, evaluate submitted proposals for inclusion under the Program. Proposals selected by the Secretary of Commerce, in consultation with the Secretary of State, the Secretary of Defense, the Secretary of Energy, and the Director of OSTP, will be designated as priority AI export packages and will be supported through priority access to the tools identified in section 4 of this order, as consistent with applicable law.
Sec. 4. Mobilization of Federal Financing Tools. (a) The Economic Diplomacy Action Group (EDAG), established in the Presidential Memorandum of June 21, 2024, chaired by the Secretary of State, in consultation with the Secretary of Commerce and the United States Trade Representative, and as described in section 708 of the Championing American Business Through Diplomacy Act of 2019 (Title VII of Division J of Public Law 116-94) (CABDA), shall coordinate mobilization of Federal financing tools in support of priority AI export packages.
(b) I delegate to the Administrator of the Small Business Administration and the Director of OSTP the authority under section 708(c)(3) of CABDA to appoint senior officials from their respective executive departments and agencies to serve as members of the EDAG.
(c) The Secretary of State, in consultation with the EDAG, shall be responsible for:
(i) developing and executing a unified Federal Government strategy to promote the export of American AI technologies and standards;
(ii) aligning technical, financial, and diplomatic resources to accelerate deployment of priority AI export packages under the Program;
(iii) coordinating United States participation in multilateral initiatives and country-specific partnerships for AI deployment and export promotion;
(iv) supporting partner countries in fostering pro‑innovation regulatory, data, and infrastructure environments conducive to the deployment of American AI systems;
(v) analyzing market access, including technical barriers to trade and regulatory measures that may impede the competitiveness of United States offerings; and
(vi) coordinating with the Small Business Administration’s Office of Investment and Innovation to facilitate, to the extent permitted under applicable law, investment in United States small businesses to the development of American AI technologies and the manufacture of AI infrastructure, hardware, and systems.
(d) Members of the EDAG shall deploy, to the maximum extent permitted by law, available Federal tools to support the priority export packages selected for participation in the Program, including direct loans and loan guarantees (12 U.S.C. 635); equity investments, co-financing, political risk insurance, and credit guarantees (22 U.S.C. 9621); and technical assistance and feasibility studies (22 U.S.C. 2421(b)).
Sec. 5. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:
(i) the authority granted by law to an executive department or agency, or the head thereof; or
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
(d) The costs for publication of this order shall be borne by the Department of Commerce.
*******
SUSPENDING DUTY-FREE DE MINIMIS TREATMENT FOR ALL COUNTRIES
July 30, 2025: By the authority vested in the President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), and section 301 of title 3, United States Code, it is hereby ordered:
Section 1. Background. In Executive Order 14193 of February 1, 2025 (Imposing Duties To Address the Flow of Illicit Drugs Across Our Northern Border), I declared a national emergency regarding the unusual and extraordinary threat to the safety and security of Americans, including the public health crisis caused by fentanyl and other illicit drugs and the failure of Canada to do more to arrest, seize, detain, or otherwise intercept drug trafficking organizations, other drug and human traffickers, criminals at large, and illicit drugs. In that order, I determined that it was necessary and appropriate to, among other things, suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for articles described in section 2(a) and section 2(b) of that order. In Executive Order 14226 of March 2, 2025 (Amendment to Duties To Address the Flow of Illicit Drugs Across Our Northern Border), I paused the suspension of duty-free de minimis treatment on such articles until I received a notification from the Secretary of Commerce (Secretary) that adequate systems are in place to fully and expeditiously process and collect duties for such articles that would otherwise be eligible for duty-free de minimis treatment.
In Executive Order 14194 of February 1, 2025 (Imposing Duties To Address the Situation at Our Southern Border), I declared a national emergency regarding the unusual and extraordinary threat to the safety and security of Americans, including the public health crisis caused by fentanyl and other illicit drugs and the failure of Mexico to do more to arrest, seize, detain, or otherwise intercept drug trafficking organizations, other drug and human traffickers, criminals at large, and illicit drugs. In that order, I determined that it was necessary and appropriate to, among other things, suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for articles described in section 2(a) of that order. In Executive Order 14227 of March 2, 2025 (Amendment to Duties To Address the Situation at Our Southern Border), I paused the suspension of duty-free de minimis treatment on such articles until I received a notification from the Secretary that adequate systems are in place to fully and expeditiously process and collect duties for such articles that would otherwise be eligible for duty-free de minimis treatment.
In Executive Order 14195 of February 1, 2025 (Imposing Duties To Address the Synthetic Opioid Supply Chain in the People’s Republic of China), I declared a national emergency regarding the unusual and extraordinary threat from the failure of the Government of the People’s Republic of China (PRC) to arrest, seize, detain, or otherwise intercept chemical precursor suppliers, money launderers, other transnational criminal organizations, criminals at large, and illicit drugs. In that order, I determined that it was necessary and appropriate to, among other things, suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for articles described in section 2(a) of that order. In Executive Order 14200 of February 5, 2025 (Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China), I paused the suspension of duty-free de minimis treatment for articles described in section 2(a) of Executive Order 14195 until I received a notification from the Secretary that adequate systems are in place to fully and expeditiously process and collect duties for such articles that would otherwise be eligible for duty-free de minimis treatment.
The President subsequently received notification from the Secretary that adequate systems have been established to process and collect duties for articles of the PRC and Hong Kong that would otherwise be eligible for duty-free de minimis treatment, and in Executive Order 14256 of April 2, 2025 (Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports), I suspended duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for products of the PRC and Hong Kong described in section 2(a) of Executive Order 14195, as amended by Executive Order 14228 (Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China). In addition, I instructed the Secretary to submit a report regarding the impact of Executive Order 14256 on American industries, consumers, and supply chains and to make recommendations for further action as he deems necessary.
In Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits), I declared a national emergency with respect to underlying conditions indicated by the large and persistent annual U.S. goods trade deficits. I also provided that duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) would remain available for products described in section 3(a) of that order until I received a notification by the Secretary that adequate systems are in place to fully and expeditiously process and collect duties applicable for articles otherwise eligible for duty-free de minimis treatment.
The Secretary has notified me that adequate systems are now in place to fully and expeditiously process and collect duties for articles otherwise eligible for duty-free de minimis treatment on a global basis, including for products described in section 2(a) and section 2(b) of Executive Order 14193, section 2(a) of Executive Order 14194, and section 3(a) of Executive Order 14257.
The President determines that it is still necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) in the manner and for the articles described below to deal with the unusual and extraordinary threats, which have their source in whole or substantial part outside the United States, to the national security, foreign policy, and economy of the United States.
The President determines that it is necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for certain Canadian goods to deal with the emergency declared in Executive Order 14193, as amended. In my judgment, this suspension is necessary and appropriate to ensure that the tariffs imposed by Executive Order 14193, as amended, are effective in addressing the emergency declared in Executive Order 14193 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14193 is not undermined. For example, many shippers go to great lengths to evade law enforcement and hide illicit substances in imports that go through international commerce. These shippers conceal the true contents of shipments sent to the United States through deceptive shipping practices. Some of the techniques employed by these shippers to conceal the true contents of the shipments, the identity of the distributors, and the country of origin of the imports include the use of re-shippers in the United States, false invoices, fraudulent postage, and deceptive packaging. The risks of evasion, deception, and illicit-drug importation are particularly high for low-value articles that have been eligible for duty-free de minimis treatment.
The President determines that it is necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for certain Mexican goods to deal with the emergency declared in Executive Order 14194, as amended. In my judgment, and for substantially similar reasons as above, this suspension is necessary and appropriate to ensure that the tariffs imposed by Executive Order 14194, as amended, are effective in addressing the emergency declared in Executive Order 14194 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14194 is not undermined.
Independently, and after considering information newly provided by the Secretary, among other things, the President determines that it is still necessary and appropriate to continue to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for certain goods of the PRC and Hong Kong to deal with the emergency declared in Executive Order 14195, as amended. In my judgment, and for substantially similar reasons as above, this suspension is still necessary and appropriate to ensure that the tariffs imposed by Executive Order 14195, as amended, are effective in addressing the emergency declared in Executive Order 14195 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14195 is not undermined.
Also independently, The President determines that it is necessary and appropriate to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) on a global basis to deal with the emergency declared in Executive Order 14257, as amended. In my judgment, this suspension is necessary and appropriate to ensure that the tariffs imposed by Executive Order 14257, as amended, are not evaded and are effective in addressing the emergency declared in Executive Order 14257 and that the purpose of this action and other actions to address the emergency declared in Executive Order 14257 is not undermined.
Each of the Presidents determinations to suspend or continue to suspend duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) are independent from the other. And each determination is made only for the purpose to deal with the respective emergency and not for the purpose of dealing with another emergency.
Sec. 2. Suspension of Duty-Free de minimis Treatment. (a) The duty-free de minimis exemption provided under 19 U.S.C. 1321(a)(2)(C) shall no longer apply to any shipment of articles not covered by 50 U.S.C. 1702(b), regardless of value, country of origin, mode of transportation, or method of entry. Accordingly, all such shipments, except those sent through the international postal network, shall be subject to all applicable duties, taxes, fees, exactions, and charges. International postal shipments not covered by 50 U.S.C. 1702(b) shall be subject to the duty rates described in section 3 of this order. Entry for all shipments that — prior to the effective date of this order — qualified for the de minimis exemption, except for shipments sent through the international postal network, shall be filed using an appropriate entry type in the Automated Commercial Environment (ACE) by a party qualified to make such entry.
(b) Shipments sent through the international postal network that would otherwise qualify for the de minimis exemption under 19 U.S.C. 1321(a)(2)(C) shall pass free of any duties except those specified in section 3 of this order, and without the preparation of an entry by U.S. Customs and Border Protection (CBP), until such time as CBP establishes a new entry process and publishes that process in the Federal Register.
Sec. 3. Duty Rates for International Postal Shipments. (a) Transportation carriers delivering shipments to the United States through the international postal network, or other parties if qualified in lieu of such transportation carriers, must collect and remit duties to CBP using the methodology described in either subsection (b) or (c) of this section. Each transportation carrier shall apply the same methodology across all covered shipments during any given period but may change its methodology no more than once per calendar month, or on another schedule determined to be appropriate by CBP, upon providing at least 24 hours’ notice to CBP.
(b) A duty equal to the effective IEEPA tariff rate applicable to the country of origin of the product shall be assessed on the value of each dutiable postal item (package) containing goods entered for consumption.
(c) A specific duty shall be assessed on each package containing goods entered for consumption, based on the effective IEEPA tariff rate applicable to the country of origin of the product as follows:
(i) Countries with an effective IEEPA tariff rate of less than 16 percent: $80 per item;
(ii) Countries with an effective IEEPA tariff rate between 16 and 25 percent (inclusive): $160 per item; and
(iii) Countries with an effective IEEPA rate above 25 percent: $200 per item.
(d) For all international postal shipments subject to the methodologies described in subsections (b) and (c) of this section, the country of origin of the article must be declared to CBP.
(e) The specific duty methodology provided for in subsection (c) of this section shall be available for transportation carriers to select for a period of 6 months from the effective date of this order. After such time all shipments to the United States through the international postal network must comply with the ad valorem duty methodology in subsection (b) of this section.
(f) Shipments sent through the international postal network that are subject to antidumping and countervailing duties or a quota must continue to be entered under an appropriate entry type in ACE to the extent required by all applicable regulations.
Sec. 4. Implementation. (a) The requirements and procedures established by sections 2 and 3 of this order shall be effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 29, 2025.
(b) The provisions of this order supersede section 2 of Executive Order 14256, as amended, with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 29, 2025.
(c) Consistent with applicable law, the Secretary of Homeland Security is directed and authorized to take all necessary actions to implement and effectuate this order — including through temporary suspension or amendment of regulations or through notices in the Federal Register and by adopting rules, regulations, or guidance — and to employ all powers granted to the President by IEEPA as may be necessary to implement and effectuate this order. The Secretary of Homeland Security, in consultation with the United States International Trade Commission (ITC), shall determine whether modifications to the Harmonized Tariff Schedule of the United States are necessary to effectuate this order and may make such modifications through notice in the Federal Register. The Secretary of Homeland Security shall consult with the Secretary of State, the Secretary of the Treasury, the Attorney General, the Secretary of Commerce, the United States Trade Representative, the ITC, and the Postmaster General, where appropriate. The Secretary of Homeland Security may, consistent with applicable law, redelegate any of these functions within the Department of Homeland Security. All executive departments and agencies shall take all appropriate measures within their authority to implement this order.
(d) To ensure remittance of duties in accordance with this order, and to assure compliance with other legal requirements, CBP is authorized to require a basic importation and entry bond as described in 19 C.F.R. 113.62 for informal entries valued at or less than $2,500. Any carrier that transports international postal shipments to the United States, by any mode of transportation, must have an international carrier bond as described in 19 C.F.R. 113.64 to ensure payment of the duties described in section 3 of this order. CBP is authorized to ensure that the international carrier bonds required by this subsection are sufficient to account for the duties described in section 3 of this order.
Sec. 5. Definition. As used in this order, the term “effective IEEPA tariff rate” means the total duty rate imposed on articles to address a national emergency declared under IEEPA, including Executive Order 14257, as amended; Executive Order 14193; as amended, Executive Order 14194, as amended; and Executive Order 14195, as amended, in accordance with the stacking rules set out in Executive Order 14289 of April 29, 2025 (Addressing Certain Tariffs on Imported Articles), and any subsequent order or proclamation addressing stacking or the applicability of tariffs imposed under IEEPA.
Sec. 6. Severability. (a) If any provision of this order or the application of any provision of this order to any individual or circumstance is held to be invalid, the remainder of this order and the application of its provisions to any other individuals or circumstances shall not be affected.
(b)(i) If the additional duties imposed under Executive Order 14193, as amended, Executive Order 14194, as amended, Executive Order 14195, as amended, or Executive Order 14257, as amended, are held to be invalid, the suspension of, or continued suspension of, duty-free de minimis treatment, as detailed in this order, shall not be affected. Duty-free de minimis treatment would still be suspended, whether pursuant to my authority under 50 U.S.C. 1702(a)(1)(B) to “regulate . . . importation” or my authority under that provision to “nullify” or “void” “exercising any right . . . or privilege with respect to . . . any property,” in the way and to the extent explained in this order, to deal with the emergencies declared in Executive Order 14193, as amended, Executive Order 14194, as amended, Executive Order 14195, as amended, or Executive Order 14257, as amended. Such suspensions are still necessary and appropriate to address the unusual and extraordinary threats to the national security, foreign policy, and economy of the United States. Each determination to suspend or continue to suspend duty-free de minimis treatment is still independent from the other determination and made only with the purpose to deal with the respective emergency and not for the purpose of dealing with another emergency. CBP is directed and authorized to take all necessary actions consistent with applicable law to implement and effectuate this order in line with this section ‑- including through temporary suspension or amendment of regulations or through notices in the Federal Register and by adopting rules, regulations, or guidance — and to employ all powers granted to the President by IEEPA as may be necessary to implement and effectuate this order in line with this section.
(ii) Duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) shall remain available for postal shipments until notification by the Secretary to the President that adequate systems are in place to fully and expeditiously process and collect duties applicable for postal shipments otherwise eligible for duty-free de minimis treatment. After such notification, duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) shall not be available for postal shipments.
Sec. 7. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:
(i) the authority granted by law to an executive
department or agency, or the head thereof; or
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
(d) The costs for publication of this order shall be borne by the Department of Homeland Security.
*******
Department of State, Directorate of Defense Trade Controls (DDTC)
International Traffic in Arms Regulations: Updates to § 126.1 Country Policies and Minor Revisions
July 7, 2025: 90 Fed. Reg. 29720: DDTC has published a final rule in the Federal Register updating the International Traffic in Arms Regulations’ (ITAR) § 126.1 country policies for the Central African Republic, the Democratic Republic of the Congo, Haiti, Libya, Somalia, South Sudan, and Sudan. These updates codify in the ITAR recent United Nations Security Council resolutions. The Department is also making several clarifications and corrections in the ITAR, including updates to the list of North Atlantic Treaty Organization (NATO) members and major non-NATO allies, as well as revising ITAR § 126.1(a) to improve its readability.
The changes are summarized as follows:
(1) Removing a requirement to pre-notify the DRC Sanctions Committee of shipments of arms and related materiel to the government of the Democratic Republic of the Congo;
(2) Permitting case-by-case consideration of exports to Haiti of (a) defense articles and services that have been pre-approved by the UN Security Council Haiti Sanctions Committee and (b) non-lethal military equipment only for humanitarian or protective use and related technical assistance or training;
(3) Implementing revisions of the UN arms embargo on Libya, including permitting specified exports and temporary exports;
(4) Implementing a Dec. 1, 2023, UNSC resolution formally lifting the prior nationwide arms embargo on Somalia;
(5) Implementing a July 30, 2024, UNSC resolution easing the arms embargo on the Central African Republic;
(6) Removing a provision that had allowed for a case-by-case review of export licenses or other approvals involving help and supplies in support of implementation of a peace agreement in Sudan;
(7) Implementing UNSC resolutions regarding the arms embargo on South Sudan;
(8) Updating the list of North Atlantic Treaty Organization members to add Finland and Sweden; and
(9) Updating the list of major non-NATO allies by adding Colombia, Kenya, and Qatar and removing Afghanistan.
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events and
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=ebdaa39697ea6a5067b1791ad053af05
*******
ITAR Updates to Certain Proscribed Countries and Other Changes – Affected Sections Redline and Updated ITAR Reorg Redline
July 8, 2025: 90. Fed. Reg. 29720: On July 7, 2025, the Department published a final rule (90 FR 29720) amending ITAR sections 120.23, 120.54, and 126.1. To assist users of the ITAR, the Department provides here a redline of sections affected by that rule and a link to the updated ITAR Reorg redline.
DDTC provides these redlines as a service to the public but notes that it is not intended to be a substitute for any official publication of the U.S. Government. We direct your attention to the annual edition of the Code of Federal Regulations and to the e-CFR system for the actual regulatory text.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=8f89a87e9722629067b1791ad053afc1
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=c6090afa97b266100083b3b0f053af2c
*******
Updating Cuba Restricted List
July 14, 2025: 90. Fed. Reg. 31558: The Department of State added seven Cuban military-controlled hotels to the List of Restricted Entities and Sub entities Associated With Cuba (Cuba Restricted List or CRL) identifying entities and sub entities under the control of, or acting for or on behalf of, the Cuban military, intelligence, or security services or personnel with which direct financial transactions would disproportionately benefit such services or personnel at the expense of the Cuban people or private enterprise in Cuba. The Cuban Assets Control Regulations generally prohibit a person subject to U.S. jurisdiction from having direct financial transactions with the entities and sub entities on the CRL. The Department of Commerce's Bureau of Industry and Security generally will deny applications to export or reexport items for use by entities or sub entities on the CRL.
https://www.federalregister.gov/documents/2025/07/14/2025-13149/updating-cuba-restricted-list
*******
DDTC Name And Address Changes Posted To Website
July 2 through July 14, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in Address of Saab AB (publ), Business Area Surveillance from Nettovagen 6, SE-175 88 Jarfalla, Sweden to Solna strandvag 10, SE 171 54 Solna, Sweden;
- Change in Name of Piaggio Aero Industries S.p.A to Baykar Aerospace S.p.A due to acquisition;
- Change in Name of Bollore Logistics SE to CEVA Air & Ocean International SE due to acquisition;
- Change in Name of Econocom Workplace Infra Innovation to Econocom Services & Solutions due to corporate restructuring;
- Change in Name of ATLAS ELEKTRONIK UK Limited to TKMS ATLAS UK Limited due to merger.
*******
DDTC Frequently Asked Questions (FAQs)
Q: Are individuals who are recipients of grants issued in accordance with the Deferred Action for Childhood Arrivals (DACA) policy of the United States Government considered U.S. persons under the ITAR?
A: No, individuals granted DACA status do not fall withing the ITAR definition of a U.S. person (ITAR § 120.62) by virtue of the issuance of their DACA status. Issuance of an employment authorization document by U.S. Citizenship and Immigration Services to such recipients does not mean that an individual is a lawful permanent resident or a protected individual as defined in 8 U.S.C. § 1101(a)(2) or 8 U.S.C. § 1324b(a)(3).
Q: Is a U.S. person who is also a citizen of another country a U.S. person, a foreign person, or both?
A: Under the ITAR, a person is either a U.S. person or a foreign person. If a person meets the definition of a U.S. person at ITAR § 120.62, by definition they are not a foreign person as defined in ITAR § 120.63. This means that a U.S. person who is a citizen of a foreign country (e.g., a lawful U.S. permanent resident who is not a U.S. citizen) is a U.S. person and not a foreign person. Similarly, a U.S. person who is a U.S. citizen and also holds the citizenship of another country is a U.S. person and not a foreign person.
Q: When is a foreign person considered an employee?
A: A foreign person is considered an employee when the foreign person is a full time regular employee, directly paid, insured, hired/fired and/or promoted exclusively by the U.S. person. The employee, however, need not LIVE in the U.S. to be employed by the U.S. person. The U.S. person is liable to ensure all foreign person employees are compliant with U.S. export laws regardless of residence.
Q: Should freight forwarders be identified on agreements (TAAs, MLAs, WDAs)?
A: Freight forwarders should not be identified in agreement submissions. Freight forwarders should only be identified in licenses in furtherance of (IFO) an agreement. See the DDTC Agreement Guidelines when utilizing the § 123.16(b) exemption regarding how to identify freight forwarders.
Q: On what type of export authorization from DDTC should the Applicant identify foreign freight forwarders that will move hardware from a foreign signatory of a Warehousing and Distribution Agreement (WDA) to an authorized end user in the Distribution Territory of that WDA?
A: The foreign freight forwarders should be identified on the DSP-5 in furtherance of the WDA for the original export of the hardware from a U.S. signatory to a foreign signatory of the WDA. Alternatively, such foreign freight forwarders can be included as sublicensees to the WDA. Lastly, a foreign signatory to the WDA may obtain retransfer/reexport authorization from DDTC to identify the foreign freight forwarders that transport the hardware to the authorized end user in the Distribution Territory of the WDA.
Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To Lebanon
July 11, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Lebanon has requested to buy support equipment, and other related elements of logistics program and support that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $43.7 million ($0 in MDE), included Cartridge Actuated Devices and Propellent Actuated Devices (CAD/PADs); engine components, parts, and accessories; aircraft engine and ground handling equipment; major and minor modifications; aircraft components, spares, and accessories; spare parts, consumables, and accessories, and repair and return support; unclassified software delivery and support; unclassified publications and technical documentation; clothing, textiles, and individual equipment; transportation support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $100 million.
The principal contractor will be Sierra Nevada Corporation (SNC), located in Sparks, NV. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
*******
DSCA Notifies Congress of Potential FMS Sale To Norway
July 11, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Norway has requested to buy up to nine (9) HH-60W helicopters; twenty-two (22) T-700-GE-401 turboshaft engines; twenty-one (21) Embedded Global Positioning System/Inertial Navigation Systems (GPS/INS) (EGI) (18 installed, 3 spares); ten (10) AN/APR-52 Radar Warning Receivers (RWR) (9 installed, 1 spare); and ten (10) AN/AAR-57 Common Missile Warning Systems (CMWS) (9 installed, 1 spare). The following non-MDE items will also be included: GAU-21 aircraft machine guns and other machine guns; IZLID 200P infrared lasers; AN/ALE-47 Airborne Countermeasures Dispenser Systems; Joint Mission Planning System with unique planning components and software; Computer Program Identification Numbers (CPINs); weapons and weapons support equipment; major and minor modifications and maintenance support; instruments and lab equipment; training aids, devices, and spare parts; consumables, accessories, and repair and return support; electronic warfare database support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; aircraft ferry and transportation support; facilities and construction support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $2.6 billion. The principal contractor will be Sikorsky Aircraft Corporation, located in Stratford, CT. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to Norway.
*******
DSCA Notifies Congress of Potential FMS Sale To Bulgaria
July 21, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Bulgaria has requested to buy a Naval Strike Missile Coastal Defense System (NSM CDS), including three (3) Link-16 Multifunctional Information Distribution System – Joint Tactical Radio Systems (MIDS-JTRS) and the following non-MDE items: tactical Naval Strike Missiles (NSM); inert NSM handling; telemetered NSM; operational, inert NSM; mobile fire control centers with associated communications equipment; mobile missile launch vehicles with associated communications equipment; NSM transport loading vehicles; NavStrike-M Global Positioning System receiver; operator trainer consoles; Simple Key Loaders (SKL); and associated support including but not limited to technical publications, training documentation, technical data packages, support equipment, software support spare parts, training, training simulators, integration services, and U.S. government and original equipment manufacturer technical assistance; and other related elements of logistics and program support. The estimated total cost is $620 million. The principal contractor will be Kongsberg Defence and Aerospace AS, located in Kongsberg, Norway. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
*******
DSCA Notifies Congress of Potential FMS Sale To Ukraine
July 23, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy sustainment related articles and services for the HAWK missile system, including: five-ton cargo trucks; HAWK system spare parts; refurbishment and system overhaul of HAWK air defense fire units; tool kits; test equipment; support equipment; technical documentation; training; U.S. Government and contractor technical and field office support; U.S. Government and contractor technical assistance; storage containers and equipment related to spare parts storage; MIM-23 HAWK missile spare parts and missile repair; and other related elements of logistics and program support. The estimated total program cost is $172 million. The principal contractors will be Sielman Corporation, located in Volos, Greece; RTX Corporation, located in Andover, MA; and PROJECTXYZ, located in Huntsville, AL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
*******
DSCA Notifies Congress of Potential FMS Sale To Ukraine
July 23, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services for the refurbishment of Bradley Infantry Fighting Vehicles, technical assistance, training, publications, and other related elements of logistics and program support. The estimated total cost is $150 million. The principal contractors will be BAE Systems, Cummins Inc., Leonardo DRS Inc., and Renk Group AG, with all work occurring in Europe. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
*******
DSCA Notifies Congress of Potential FMS Sale To Ukraine
July 24, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services to support the training, sustainment, and refurbishment measures of existing U.S.-origin air defense systems. The following non-MDE items will be included: major modifications and maintenance support; spare parts, consumables and accessories, and repair and return support; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $180 million. The principal contractors will be Sierra Nevada Corporation, located in Sparks, NV; V2X, Inc., located in McLean, VA; Radionix, located in Kyiv, Ukraine; and Systems Electronic Export, located in Kyiv, Ukraine. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
*******
DSCA Notifies Congress of Potential FMS Sale To Ukraine
July 24, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Ukraine has requested to buy equipment and services for the refurbishment of M109 self-propelled howitzers, technical assistance, training, publications, and other related elements of logistics and program support. The estimated total cost is $150 million. The principal contractors will be BAE Systems, Daimler Truck North America, and Allison Transmission Inc., with all work occurring in Europe. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
*******
DSCA Notifies Congress of Potential FMS Sale To Egypt
July 24, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Egypt has requested to buy the National Advanced Surface-to-Air Missile System (NASAMS), that includes: four (4) AN/MPQ-64F1 Sentinel radar systems with associated support equipment; one hundred (100) Advanced Medium Range Air-to-Air Missiles (AMRAAM)-Extended Range (ER); one hundred (100) Air Intercept Missile (AIM)-120C-8 AMRAAMs; two (2) AIM-120C-8 AMRAAM guidance sections (spares); one (1) AMRAAM control section (spare); six hundred (600) AIM-9X Sidewinder Block II tactical missiles; one hundred fifty (150) AIM-9X Sidewinder Captive Air Training Missiles (CATMs); sixty-two (62) AIM-9X Sidewinder Block II tactical guidance units (GUs); and twenty (20) AIM-9X Sidewinder CATM GUs. The following non-MDE items will also be included: fire distribution centers (FDC); canister launcher systems; electrooptical/infrared systems; Tactical Control Center systems; NASAMS classroom trainer; communication node systems; IPS 250X High Assurance Internet Protocol Encryptions (HAIPE); Identification Friend or Foe (IFF) Model 5800 or TPX-61; KIV-77 IFF crypto appliqué; AN/PSN-13 Defense Advanced Global Positioning System Receivers (DAGRs) with Selective Availability Anti-Spoofing Module (SAASM); AN/PYQ-10 Simple Key Loaders (SKLs), code loaders, and cable sets; AMRAAM-ER Extended Load Trainers (ELTs); missile containers; weapon system support and test equipment; spare and repair parts, consumables, accessories, and repair and return support; publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $4.67 billion. The prime contractor will be RTX Corporation, located in Andover, MA. There are no known offset agreements proposed in connection with this potential sale.
*******
U.S. Census Bureau
Schedule B and Harmonized Tariff Schedule (HTS) Updated in the Automated Export System (AES)
July 2, 2025:
Effective immediately, the Schedule B, Harmonized Tariff Schedule (HTS), and HTS Codes That Are Not Valid for AES tables have been updated to accept the changes to the July 1, 2025 codes.
AES will accept shipments with outdated codes during a grace period for 30 days beyond the expiration date of June 30, 2025. Reporting an outdated code after the 30-day grace period will result in a fatal error.
The ACE AESDirect program has been updated with the 2025 codes and will accept shipments with outdated codes during the grace period as well.
The 2025 Schedule B and HTS tables are available for downloading at:
https://www.census.gov/foreign-trade/aes/concordance.html
The current list of HTS codes that are not valid for AES are available at:
https://www.census.gov/foreign-trade/aes/documentlibrary/concordance/hts-not-for-aes.txt
*******
Update to Automated Export System (AES) Response Message 15A
July 2, 2025:
CSMS # 65520566 - Update to Automated Export System (AES) Response Message 15A
This message is a follow-up to the broadcast released on May 11, 2022, titled Expansion of Foreign Trade Zone Identifier to 9-characters (Effective May 17, 2022).
The severity of Response Message 15A is being upgraded from “Compliance” to a severity of “Fatal” July 14, 2025. This is to ensure further compliance with the changes outlined in Federal Register Notice 85 FR 60479 that requires the expansion of the Foreign Trade Zone Identifier from 7 to 9-characters. This change is effective immediately in CERT for testing.
Response Code: 15A
Narrative Text: FTZ MUST BE 9 CHARACTERS ALPHANUMERIC
Severity: FATAL
Reason: The Foreign Trade Zone Indicator reported on the SC2 record does not have the required format of 3 numeric characters which is a valid zone followed by 6 alphanumeric characters.
Resolution: The Foreign Trade Zone Indicator must be specified in the required format. The first 3 positions must be numeric and represent the general purpose zone. The next 3 positions are alphanumeric and represent the subzone. The last 3 positions are alphanumeric and represent the site. The Foreign Trade Zone Indicator must be left justified with no trailing spaces. Insert zeros when there is no sub zone or site. Report leading zero(s) when the general purpose zone is less than 3 numerics, and when the subzone or site is 1 alphanumeric. Verify the Foreign Trade Zone Indicator, correct the SC2 record and retransmit.
Contact your assigned CBP Client Representative for programming and testing questions.
*******
How to Resolve Common AES Response Messages
July 15, 2025:
When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning. It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations
To help you take the appropriate action, here is guidance on how to address one of the most frequent Response Messages that were generated in the AES for the previous month.
Response Code: 628
Narrative: 1st Unit of Measure Code / Schedule B/HTS Mismatch
Severity: Fatal
Reason: The Unit of Measure (1) reported does not match the Unit of Measure (1) required for the Schedule B/ HTS Number reported.
Resolution: The Unit of Measure (1) must match exactly the Unit of Measure (1) prescribed by the Schedule B/HTS Number reported. See Appendix K – Units of Measure Codes
Verify the Unit of Measure (1) required for the reported Schedule B/HTS Number, correct the shipment and resubmit.
For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.
*******
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
Department of Commerce, Bureau of Industry and Security (BIS)
July 2, 2025: The Bureau of Industry and Security, U.S. Department of Commerce has notified Unicat Catalyst Technologies, LLC, of Alvin, Texas, as successor to Unicat Catalyst Technologies, Inc., (“Unicat”), of its intention to initiate an administrative proceeding against Unicat pursuant to Section 766.3 of the Export Administration Regulations (the “Regulations”), through the issuance of a Proposed Charging Letter to Unicat that alleges that Unicat committed three violations of the Regulations.
https://media.bis.gov/news-updates
https://media.bis.gov/media/1635
*******
July 21, 2025: Brian Assi, also known as Brahim Assi, 63, of Beirut, Lebanon, was sentenced to 44 months in prison for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR), attempted unlawful export of goods from the United States to Iran without a license, attempted smuggling goods from the United States, submitting false or misleading export information, and conspiracy to commit money laundering.
*******
July 21, 2025: José Adolfo Macías Villamar, also known as “Fito,” a citizen of Ecuador, was arraigned at the federal courthouse in Brooklyn for crimes committed as the leader of Los Choneros, a transnational criminal organization based in Ecuador that is responsible for significant drug trafficking into the United States, firearms trafficking from the United States, and acts of extreme violence. Macías Villamar was arraigned on a seven-count superseding indictment charging him with international cocaine distribution conspiracy; international cocaine distribution; using firearms in furtherance of drug trafficking; smuggling firearms from the United States; and straw purchasing of firearms conspiracy. Macías Villamar will be arraigned before United States Chief Magistrate Judge Vera M. Scanlon after being extradited from Ecuador to the Eastern District of New York.
https://media.bis.gov/news-updates
*******
July 28, 2025: The Department of Commerce’s Bureau of Industry and Security (BIS) imposed an administrative penalty of $95 million against Cadence Design Systems Inc. (Cadence) for illegal exports of Electronic Design Automation (EDA) hardware and software and semiconductor design technology to parties on the Entity List, an export controls blacklist. This is in addition to a concurrent agreement that Cadence signed with the U.S. Department of Justice which includes $45 million in forfeitures.
In a settlement agreement with BIS, Cadence admitted that employees of its Chinese subsidiary knowingly transferred sensitive U.S. technology to entities that develop supercomputers in support of China’s military modernization and nuclear weapons programs namely the National University of Defense Technology (NUDT), Tianjin Phytium Information Technology (Phytium), and other Entity List parties.
Under the terms of the BIS settlement agreement, Cadence admitted to 56 violations of the EAR between September 2015 and September 2020, for selling EDA products to NUDT through an alias, Central South CAD Center (CSCC). Cadence exported EDA hardware and software, and semiconductor design technology, valued at $45,305,317.41 to CSCC with knowledge or reason to know that NUDT would be the end-user. Cadence maintained a sales relationship with NUDT for years after NUDT’s placement on the Entity List using an account assigned to CSCC and had reason to know CSCC was closely linked to NUDT, including that equipment sold or loaned to CSCC was installed on the NUDT campus and that CSCC and NUDT shared personnel.
https://bis.gov/media/documents/cadence-design-systems-final-order-7.28.2025.pdf
*******
Department of the Treasury, Office of Foreign Assets Control (OFAC)
July 2, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $608,825 settlement with Key Holding, LLC. Key Holding agreed to settle its potential civil liability for 36 apparent violations of OFAC sanctions on Cuba that arose from the conduct of a Key Holding subsidiary in Colombia that managed the logistics for freight shipments to Cuba. The settlement amount reflects OFAC's determination that the apparent violations were non-egregious and voluntarily self-disclosed. For more information, please see the following Enforcement Release.
https://ofac.treasury.gov/recent-actions/20250702
https://ofac.treasury.gov/media/934456/download?inline
*******
July 8, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $1,454,145 settlement with Harman International Industries, Inc. Harman agreed to settle its potential civil liability for 11 apparent violations of OFAC sanctions on Iran. Over a period of more than two years, overseas employees of a U.S. subsidiary of Harman enabled the diversion of its products from its United Arab Emirates distributor to Iran. The settlement amount reflects OFAC's determination that the apparent violations were egregious and voluntarily self-disclosed. For more information, please see the following Enforcement Release and settlement agreement.
https://ofac.treasury.gov/media/934471/download?inline and
https://ofac.treasury.gov/media/934476/download?inline
*******
July 15, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an $11,832,136 settlement with Interactive Brokers LLC (IB). IB agreed to settle its potential civil liability for apparent violations of several OFAC sanctions programs that arose from IB’s provision of brokerage and investment services to persons in Iran, Cuba, Syria, and the Crimea region of Ukraine, processing of trades in securities subject to the Chinese Military-Industrial Complex program, processing of transactions involving blocked persons under OFAC’s Russia, Global Magnitsky, Venezuela, and Syria sanctions programs, and engagement in new investment in the Russian Federation. OFAC determined IB’s conduct was non-egregious and voluntarily self-disclosed. For more information, please visit the following Enforcement Release.
https://ofac.treasury.gov/recent-actions/20250715
https://ofac.treasury.gov/media/934501/download?inline
*******
July 29, 2025: The Bureau of Industry and Security, U.S. Department of Commerce (“BIS”), has notified Inc., of its intention to initiate an administrative proceeding against Andritz Inc. pursuant to Section 766.3 of the Export Administration Regulations (the “Regulations”), through the issuance of a Proposed Charging Letter to Andritz Inc. that alleges that Andritz Inc. committed 36 violations of the Regulations. Specifically:
STATEMENT OF CHARGES
Charges 1 - 36 15 C.F.R. § 764.2(a) – Engaging in Prohibited Conduct
As described in the Schedule of Violations, between on or about May 25, 2023, through on or about February 12, 2024, Andritz Inc. engaged in conduct prohibited by the Regulations on 36 occasions when it exported refiner plates, valued at $3,154,794.36, to Andritz Fiedler. Andritz Fiedler then reexported the refiner plates to Russia. The sales to Russia were conducted without the requisite license or other authorization from BIS.
The items reexported by Andritz Fiedler are classified EAR99. However, because these items were classified by Harmonized Tariff Schedule (“HTS”) codes which appeared on Supplement No. 4 to Part 746 of the EAR at the time of export, these items required a license for export to Russia pursuant to § 746.8 of the EAR. On May 23, 2023, BIS added license requirements for the items to limit Russia’s access to items that enable its military capabilities and to sources of revenue that could support those capabilities. 88 Fed. Reg. 33422. Refiner plates are used in the refining process of paper pulp making machines. Paper pulp is a basic component of manufacturing paper. While there is no evidence that Andritz Inc.’s refiner plates were designed for, used, or could be used, for military-related purposes, wood and flax pulp could potentially have military application.
Supplement No. 4 to Part 746 of the Regulations identifies ‘industrial goods’ which require a BIS license for export, reexport, or transfer (in-country) to Russia or Belarus. For the purposes of this license requirement, an ‘industrial good’ is any item identified in Supplement No. 4 to Part 746 of the Regulations. The HTS classifications of the items contained in each of Andritz Inc.’s 36 exports are detailed in the Schedule of Violations below.
Upon learning of the transactions, Andritz Inc. took immediate steps to investigate the matter, voluntarily disclosed the transactions in a timely fashion to BIS, and retained outside counsel to investigate. According to information it voluntarily disclosed to BIS, Andritz Inc. exported refiner plates to Andritz Fiedler without the requisite license. Andritz Fielder then sold and shipped the refiner plates to entities within Russia.
In total, from on or about May 25, 2023, through on or about February 12, 2024, Andritz Inc. engaged in 36 transactions involving the reexport of refiner plates. Each of these transactions involved items classified by an HTS code listed in Supplement No. 4 to Part 746 of the EAR and required a license for export to Russia pursuant to § 746.8(a)(5) of the EAR.
By engaging in 36 reexports to Russia without the requisite license or other authorization from BIS, Andritz Inc. committed 36 violations of § 764.2(a) of the Regulations.
*******
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
July 1, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Aeza Group, a bulletproof hosting (BPH) services provider, for its role in supporting cybercriminal activity targeting victims in the United States and around the world. BPH service providers sell access to specialized servers and other computer infrastructure designed to help cybercriminals like ransomware actors, personal information stealers, and drug vendors evade detection and resist law enforcement attempts to disrupt their malicious activities. OFAC is also designating two affiliated companies and four individuals who are Aeza Group leaders. Finally, in coordination with the United Kingdom’s (UK) National Crime Agency (NCA), OFAC is designating an Aeza Group front company in the UK.
The following individuals have been added to OFAC’s SDN List:
- Bozoyan, Yurii Meruzhanovich of Russia;
- Gast, Valdimir Vyacheslavovich of Russia;
- Knyazev, Igor Anatolyevich of Russia; and
- Penzev, Arsenii Aleksandrovich of Russia.
The following entities have been added to OFAC’s SDN List:
- Aeza Group LLC of Russia;
- Aeza International, Ltd. of the United Kingdom;
- Aeza Logistics LLC of Russia; and
- Cloud Solutions LLC of Russia.
https://ofac.treasury.gov/recent-actions/20250701
https://home.treasury.gov/news/press-releases/sb0185
*******
July 3, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against networks that have collectively transported and purchased billions of dollars’ worth of Iranian oil, some of which has benefited Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. Among the entities sanctioned is a network of companies run by Iraqi businessman Salim Ahmed Said (Said) that has profited from smuggling Iranian oil disguised as, or blended with, Iraqi oil. Treasury also sanctioned several vessels engaged in the covert delivery of Iranian oil, intensifying pressure on Iran’s “shadow fleet.”
The following individual has been added to OFAC’s SDN List:
- Said, Salim Ahmed of the United Arab Emirates.
The following entities have been added to OFAC’s SDN List:
- Aria Sina Control International Technical Inspection Co. of Iran;
- Asian Sean Angel Shipping Co of Iran;
- Betensh Global Investment Limited and Dong Dong Shipping Limited of the Virgin Islands;
- Breeze Marine Asset Management Inc of the Marshall Islands;
- Dima Shipping and Trading Company of Turkey;
- Egir Shipping Ltd of Mahe Island;
- Fotis Lines Incorporated of the Marshall Islands;
- Grat Shipping Co Ltd of Mahe Island;
- Isle Innovation Inc of Panama;
- Keval Methanol Company of Iran;
- Rhine Shipping DMCC of the United Arab Emirates;
- Robinbest Limited of the United Kingdom;
- Sai Saburi Consulting Services Private Limited of India;
- Tashilat Sarl of India;
- The Willet Hotel Limited of the United Kingdom;
- Themis Limited of the Marshall Islands;
- Trans Arctic Global Marine Services Pte. Ltd. of Singapore;
- VS Oil Terminal FZE of the United Arab Emirates;
- VS Petroleum DMCC of the United Arab Emirates;
- VS Tankers Free Zone Entity of the United Arab Emirates; and
- White Sands Shipment Corp of Seychelles.
The following vessels have been added to OFAC’s SDN List:
- Artemis III (HQZY4) Crude Oil Tanker Honduras flag; MMSI 334983000 (vessel);
- Atila (TJM0033) Crude Oil Tanker Cameroon flag; MMSI 613769400 (vessel);
- Bateleur (HOA5120) LPG Tanker Panama flag; MMSI 352980786 (vessel);
- Bianca Joysel (3E2106) Crude Oil Tanker Panama flag; MMSI 352001069 (vessel);
- Dijilah (V7A2015) Crude Oil Tanker Marshall Islands flag; MMSI 538008147 (vessel):
- Elizabet (TJMC263) Crude Oil Tanker Cameroon flag; MMSI 613001301 (vessel);
- Fotis (D6A3948) LPG Tanker Comoros flag; MMSI 620999948 (vessel);
- Gas Maryam (T8A4824) LPG Tanker Palau flag; MMSI 511101457 (vessel);
- Neel (3E2234) LPG Tanker Panama flag; MMSI 352002246 (vessel);
- Rieveria I (T7BC7) Crude Oil Tanker San Marino flag; MMSI 268245201 (vessel);
- Themis (3EFU8) Crude Oil Tanker Panama flag; MMSI 353744000 (vessel); and
- VIZURI (TJMC707) Crude Oil Tanker Cameroon flag; MMSI 613742000 (vessel).
https://ofac.treasury.gov/recent-actions/20250703
https://home.treasury.gov/news/press-releases/sb0188
*******
July 3, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned seven senior officials and one entity associated with the Hizballah-controlled financial institution Al-Qard Al-Hassan (AQAH), which was designated by OFAC in 2007. These officials have served in senior management roles for AQAH and have facilitated the evasion of U.S. sanctions, enabling Hizballah’s access to the formal financial system. This action underscores Treasury’s commitment to disrupting Hizballah’s sanctions evasion schemes and supporting efforts by the new Lebanese government to limit the terrorist group’s influence, particularly as entities like AQAH continue to undermine the already fragile Lebanese economy.
The following individuals have been added to OFAC’s SDN List:
- Badir, Mohammed Suleiman of Lebanon;
- Bezz, Imad Mohammad of Lebanon;
- Fawaz, Samer Hasan of Lebanon;
- Jamil, Nehme Ahmad of Lebanon;
- Karnib, Ali Mohamad of Lebanon;
- Kassir, Issa Hussein of Lebanon;
- Krishi, Ali Ahmad of Lebanon; and
- Said, Salim Ahmed of Lebanon.
https://home.treasury.gov/news/press-releases/sb0189
https://ofac.treasury.gov/recent-actions/20250703
*******
July 7, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40D, "Authorizing the Offloading of Liquefied Petroleum Gas in Venezuela."
GENERAL LICENSE NO. 40D: “Authorizing the Offloading of Liquefied Petroleum Gas in Venezuela”
- All transactions that are ordinarily incident and necessary to the delivery and offloading of liquefied petroleum gas in Venezuela, involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, that are prohibited by Executive Order (E.O.) 13850 of November 1, 2018, as amended by E.O. 13857 of January 25, 2019, or E.O. 13884 of August 5, 2019, each as incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized through 12:01 a.m. eastern daylight time, September 5, 2025, provided the liquified petroleum gas was loaded on a vessel on or before July 7, 2025.
https://ofac.treasury.gov/media/934461/download?inline
https://ofac.treasury.gov/recent-actions/20250707
*******
July 8, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related General License 13N, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024."
GENERAL LICENSE NO. 13N: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”
- S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, October 9, 2025.
https://ofac.treasury.gov/media/934466/download?inline
https://ofac.treasury.gov/recent-actions/20250708
*******
July 8, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Song Kum Hyok, (Song), a malicious cyber actor associated with the sanctioned Democratic People’s Republic of Korea (DPRK) Reconnaissance General Bureau (RGB) hacking group Andariel.
The following individuals have been added to OFAC’s SDN List:
- Asatryan, Gayk of Russia; and
- Song, Kum Hyok of North Korea.
The following entities have been added to OFAC’s SDN List:
- Asatryan Limited Liability Company of Russia;
- Fortuna Limited Liability Company of Russia;
- Korea Saenal Trading Corporation of North Korea; and
- Korea Songkwang Trading General Corporation of North Korea.
https://ofac.treasury.gov/recent-actions/20250708_33
*******
July 8, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 13N, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.”
GENERAL LICENSE NO. 13N: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”
- S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, October 9, 2025.
https://ofac.treasury.gov/media/934466/download?inline
https://ofac.treasury.gov/recent-actions/20250708
*******
July 9, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 22 entities based in Hong Kong, the United Arab Emirates (UAE), and Türkiye for their roles in facilitating the sale of Iranian oil that benefits the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). The IRGC-QF is Iran’s most powerful paramilitary force and a designated Foreign Terrorist Organization (FTO).
The following entities have been added to OFAC’s SDN List:
- Amito Trading Limited of China;
- Bright Spot Goods Wholesalers of the United Arab Emirates;
- Cetto International Limited of Hong Kong;
- Finesse Global Trading Limited of China;
- Future Resource Trading Limited of China;
- Gah Petrochemical Trading Limited of China;
- Golden Globe Demir Celik Petrol Sanayi Ve Ticarat Anonim Sirketi of Turkey;
- JTU Energy Limited of China;
- Lavida Corporation Limited of China;
- Marcera Internation Limited of China;
- Marmerth Limited of China;
- Matallex Limited of China;
- Mist Trading Co., Limited of China;
- Moon Imp and Exp Co., limited of China;
- Peakway Global Limited of China;
- Pulcular Enerji Sanayi Vi Ticaret Anonim Sirketi of Turkey;
- Queens Ring Limited of China;
- Radix Trade Limited of China;
- Shelf Trading Limited of China;
- Star Oilgolbal Limited of China; and
- Ventus Trade Limited of China.
https://ofac.treasury.gov/recent-actions/20250709
*******
July 9, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued ICC-related General License 8, “Authorizing the Wind Down of Transactions Involving Francesca Paola Albanese.”
GENERAL LICENSE NO. 8: “Authorizing the Wind Down of Transactions Involving Francesca Paola Albanese”
- All transactions prohibited by the International Criminal Court-Related Sanctions Regulations (ICCSR), 31 CFR part 528, that are ordinarily incident and necessary to the wind down of any transaction involving Francesca Paola Albanese (Albanese), or any entity in which Albanese owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, August 8, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the ICCSR.
The following individual has been added to OFAC’s SDN List:
- Albanese, Francesca Paola of Italy.
https://ofac.treasury.gov/recent-actions/20250709_33
*******
July 17, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Hector Rusthenford Guerrero Flores (a.k.a. “Niño Guerrero”)—the head of Tren de Aragua—and five other key Tren de Aragua leaders and affiliates. Tren de Aragua is a Foreign Terrorist Organization (FTO) that originated in Venezuela and continues to expand. Niño Guerrero has grown Tren de Aragua from a prison gang involved in extortion and bribery to an influential organization that threatens public safety throughout the Western Hemisphere. Tren de Aragua is involved in the illicit drug trade, human smuggling and trafficking, extortion, sexual exploitation of women and children, and money laundering, among other criminal activities.
The following individuals have been added to OFAC’s SDN List:
- Castillo Rondon, Felix Anner of Peru;
- Guerrero Flores, Hector Rusthenford of Venezuela;
- Perez Castillo, Wilmer Jose of Venezuela;
- Rios Gomez, Wendy Marbelys of Colombia;
- Romero, Yohan Jose of Venezuela; and
- Santana Pena, Josue Angel of Venezuela.
https://ofac.treasury.gov/recent-actions/20250717
*******
July 22, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two individuals and five entities that profit through money laundering and importing petroleum products into territory controlled by Ansarallah, commonly known as the Houthis. The Iran-backed Houthis gain hundreds of millions of dollars annually by working with Yemeni businessmen to tax petroleum imports, generating critical revenue that funds the Houthis’ destabilizing activities in the region.
The following individuals have been added to OFAC’s SDN List:
- Al Wazir, Yahya Mohammed of Yemen; and
- Al-Sunaydar, Muhammed of Yemen.
The following entities have been added to OFAC’s SDN List:
- Al-Saida Stone For Trading And Agencies of Yemen;
- Amran Cement Factory of Yemen;
- Arkan Mars Petroleum Company For Oil Products Imports of Yemen;
- Arkan Mars Petroleum DMCC of the United Arab Emirates; and
- Arkan Mars Petroleum FZE of the United Arab Emirates.
https://ofac.treasury.gov/recent-actions/20250722
*******
July 24, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Korea Sobaeksu Trading Company and three associated individuals—Kim Se Un, Jo Kyong Hun, and Myong Chol Min—for their involvement in the evasion of U.S. and United Nations (UN) sanctions and efforts to generate revenue clandestinely for the Democratic People’s Republic of Korea (DPRK) government, including through fraudulent information technology (IT) worker schemes. This action to counter the DPRK’s wide-ranging revenue generation schemes is part of a collaborative effort with the Departments of Justice, Homeland Security, and State; the Federal Bureau of Investigation; and Homeland Security Investigations.
The following individual has been added to OFAC’s SDN List:
- Jo, Kyong Hun of North Korea;
- Kim, Se Un of North Korea; and
- Myong, Chol Min of North Korea.
The following entity has been added to OFAC’s SDN List:
- Korea Sobaeksu Trading Corporation of China.
https://ofac.treasury.gov/recent-actions/20250724
https://home.treasury.gov/news/press-releases/sb0205
*******
June 25, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Cartel de los Soles (a.k.a. Cartel of the Suns) as a Specially Designated Global Terrorist. Cartel de los Soles is a Venezuela-based criminal group headed by Nicolas Maduro Moros and other high-ranking Venezuelan individuals in the Maduro regime that provides material support to foreign terrorist organizations threatening the peace and security of the United States, namely Tren de Aragua and the Sinaloa Cartel.
The following entity has been added to OFAC’s SDN List:
- Cartel De Los Soles of Venezuela.
https://ofac.treasury.gov/recent-actions/20250725
*******
July 30, 2025: In its largest Iran-related action since 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identifying more than 50 vessels that are part of the vast shipping empire controlled by Mohammad Hossein Shamkhani (Hossein). Hossein—the son of Ali Shamkhani, a top political advisor to the Supreme Leader of Iran—leverages corruption through his father’s political influence at the highest levels of the Iranian regime to build and operate a massive fleet of tankers and containerships. This network transports oil and petroleum products from Iran and Russia, as well as other cargo, to buyers around the world, generating tens of billions of dollars in profit.
The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Iran General License R, “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 30, 2025.”
GENERAL LICENSE R: “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 30, 2025”
- All transactions prohibited by Executive Order (E.O.) 13902 that are ordinarily incident and necessary to one or more of the following activities involving the blocked vessels or blocked persons listed in the Annex to this general license, and any entity in which those blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, October 1, 2025, provided that any payment to a blocked person must be made into a blocked interest-bearing account located in the United States:
(1) The safe docking and anchoring in, and departure from, any port, excluding ports located in Iran or the Russian Federation, or under the control of the Government of Iran or the Government of the Russian Federation, of the blocked vessels listed in the Annex to this general license (the “Blocked Vessels”);
(2) The preservation of the health or safety of the crew of any of the Blocked Vessels;
(3) Emergency repairs of any of the Blocked Vessels or environmental mitigation or protection activities relating to any of the Blocked Vessels; or
(4) The delivery and offloading of cargo involving the Blocked Vessels, provided that the cargo was loaded on or before July 30, 2025 and that the delivery and offloading of cargo does not occur at any port located in Iran or the Russian Federation or under the control of the Government of Iran or the Government of the Russian Federation.
Please see full list of sanctioned individuals, entities, and vessels at the link below:
https://ofac.treasury.gov/recent-actions/20250730_33
https://ofac.treasury.gov/media/934536/download?inline
*******