This newsletter is a listing of the latest changes in export control regulations through July 31, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
Securing America’s Defense Supply Chains And Ensuring Domestic Acquisition Of Critical Materials
July 20, 2026: 91 Fed. Reg. 14415: The President issued Executive Order (EO) 14415 to strengthen U.S. defense supply chains. It is the policy of the United States that not only the finished equipment deployed by our military, but also the critical materials and components necessary to manufacture, maintain, sustain, and repair that equipment, are sourced domestically or from allied nations.
The EO:
- Restricts the use of waivers that allow defense contractors and sub-contractors to source materials from U.S. adversaries.
- Authorizes the use of a waiver when a contractor submits a formal mitigation plan that identifies:
- The source of the non-compliant material;
- Documents evidencing exhaustive efforts made to acquire material from a compliant source;
- Steps to be taken by the contractor to remove the non-compliant material from its supply chain; and
- A timeline for completing the mitigation plan.
- Requires the Secretary of War to develop policy and implementation guidance to require all prime contractors and subcontractors at any tier to map and illuminate critical supply chains for all Department of War acquisitions that support, implicate, or relate to United States national security. The proposed regulations shall include requirements that:
(i) Contractors must submit to the Department of War a complete indentured Bill of Materials that traces all components, parts, equipment, software, and materials back to the origin of raw materials in their supply chains;
(ii) Contractors must establish and implement written procedures, in accordance with existing Department of War procedures for conducting supply chain risk assessments, to proactively vet all suppliers and subcontractors that support the critical supply chain; such vetting for critical supply chains shall, at a minimum, include screening of subcontractors and suppliers for the following categories of supply chain risks and challenges:
(A) financial, as defined in section 7(c) of this EO,
(B) foreign ownership, control, or influence, as defined in section 7(d) of this EO, and
(C) manufacturing and supply, as defined in section 7(e) of this EO;
(iii) Prohibit contractors from utilizing in their supply chains covered material supplied by an unreliable foreign supplier, as defined in section 7(f) of this EO; and
(iv) Contractors to track and report: vetting activities; significant supply chain risks; and mitigation activities until closure.
Details of the EO can be found at the following links.
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Department of State
Imposition of Additional Sanctions on Sudan Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991
July 20, 2026 :91 Fed. Reg. 45309: On June 23, 2026 the Under Secretary of State for Arms Control and International Security decided to impose additional sanctions on Sudan. As a result, the following additional sanctions are hereby imposed:
- Multilateral Development Bank Assistance: The United States Government shall oppose, in accordance with Section 701 of the International Financial Institutions Act (22 U.S.C. 262d), the extension of any loan or financial or technical assistance to Sudan.
The Under Secretary of State for Arms Control and International Security has determined that it is essential to the national security interests of the United States to waive the application of this sanction on loans or financial or technical assistance to Sudan that serve the basic human needs of its citizens.
- Further Export Restrictions: The authorities of section 6 of the Export Administration Act of 1979 shall be used to prohibit exports to Sudan of all other goods and technology (excluding food and other agricultural commodities and products).
The Under Secretary for Arms Control and International Security has determined that it is essential to the national security interests of the United States to waive the application of this sanction with respect to items not on the Commerce Control List (CCL). The restrictions are also partially waived in order to allow the authorization of exports or re-exports of goods or technology on the Commerce Control List (CCL) to Sudan in the following categories:
License Exceptions: Exports and re-exports of goods or technology on the CCL may be authorized under License Exceptions CCD, GOV, ENC, BAG, TMP, RPL, TSU and ACE, as described in 15 CFR part 740.
Safety of Flight: Exports and re-exports of goods or technology on the CCL may be authorized pursuant to new licenses when necessary for the safety of flight of civil fixed-wing passenger aviation, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
Deemed Exports/Re-Exports: Exports and re-exports of goods or technology on the CCL may be authorized pursuant to new licenses for deemed exports and re-exports to Sudanese nationals, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
Wholly-Owned U.S. and Other Foreign Subsidiaries: Exports and re-exports of goods or technology on the CCL may be authorized pursuant to new licenses for exports and re-exports to wholly-owned subsidiaries of U.S. and foreign companies in Sudan, provided that such licenses shall be issued consistent with export licensing policy for Sudan prior to the date of the determination.
Licenses for all other exports, reexports, or transfers (in-country) of items on the CCL to Sudan will be reviewed under a “presumption of denial.”
National security-sensitive goods and technology exports to Sudan remain subject to the sanctions under section 307(a)(5) of the Act as described in the June 27, 2025 Federal Register notice. Consistent with the above, all other licenses for the export, reexport, and transfer (in-country) of national security-sensitive goods and technology will be reviewed under a “presumption of denial.”
- Action Regarding Aviation: The Department of Transportation shall take all steps necessary to suspend the authority of foreign air carriers owned or controlled by the Government of Sudan to engage in foreign air transportation to or from the United States.
This notice is effective on July 20, 2026.
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Department of State, Directorate of Defense Trade Controls (DDTC)
30-Day Notice of Proposed Information Collection: Disclosure of Violations of the Arms Export Control Act
July 1, 2026: 91 Fed. Reg. 40085: The Directorate of Defense Trade Controls (DDTC) is soliciting public comments to permit the evaluation of a form for the submission of voluntary disclosures. DDTC will accept comments up to July 31, 2026.
DDTC encourages voluntary disclosures of violations of the Arms Export Control Act (AECA) its implementing regulations, the International Traffic in Arms Regulations (ITAR), and any regulation, order, license, or other authorization issued thereunder. The information disclosed is analyzed by DDTC to ultimately determine whether to take administrative action concerning any violation that may have occurred. Voluntary disclosures may be considered a mitigating factor in determining the administrative penalties, if any, that may be imposed. Failure to report a violation may result in circumstances detrimental to U.S. national security and foreign policy interests and will be an adverse factor in determining the appropriate disposition of such violations. Also, the activity in question might merit referral to the Department of Justice for consideration of whether criminal prosecution is warranted. In such cases, DDTC will notify the Department of Justice of the voluntary nature of the disclosure, but the Department of Justice is not required to give that fact any weight.
ITAR § 127.12 describes the information which should accompany a voluntary disclosure. Historically, respondents to this information collection submitted their disclosures to DDTC in writing via hard copy documentation. However, as part of an IT modernization project designed to streamline the collection and use of information by DDTC, a discrete form has been developed for the submission of voluntary disclosures. This will allow both DDTC and respondents submitting a disclosure to more easily track submissions.
DDTC is soliciting public comments to permit the DDTC to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
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30-Day Notice of Proposed Information Collection: Brokering Approval (License)
July 7, 2026: 91 Fed. Reg. 41725: The Directorate of Defense Trade Controls (DDTC) is soliciting public comments to permit the evaluation of information collected in connection with brokering. DDTC will accept comments up to August 6, 2026.
In accordance with part 129 of the ITAR, U.S. and foreign persons who wish to engage in ITAR-controlled brokering activity of defense articles and defense services must first register with DDTC. Brokers must then submit a written request for approval to DDTC and receive DDTC’s approval prior to engaging in such activities, unless exempted. This information is currently used in the review of the brokering request submitted for approval and to ensure compliance with defense trade statutes and regulations. It is also used to monitor and control the transfer of sensitive U.S. technology.
Applicants may submit a Brokering Approval Request electronically via DDTC’s Defense Export Control and Compliance System (DECCS), using the DS-4294.
DDTC is soliciting public comments to permit the Department to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
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U.S. Department of State Issues a Press Release Regarding the Issuance of an Interim Final Rule to Eliminate Burdensome Regulations on Firearms Suppressors
July 22, 2026: In support of the President’s Executive Order on Reforming Foreign Defense Sales to Improve Speed and Accountability, the Department has issued an interim final rule that will remove certain firearm silencers, mufflers, and sound suppressors from the International Traffic in Arms Regulations (ITAR)’s U.S. Munitions List (USML). The export of these items will be controlled by the Department of Commerce’s Bureau of Industry and Security (BIS). This action eliminates unnecessary and burdensome regulations and aligns export controls on suppressors with the controls already applied to firearms.
This action eliminates unnecessary regulations and aligns export controls on suppressors with the standard controls already applied to firearms. In doing so, this proposed rule further enables U.S. industry to compete in the global marketplace with foreign producers of these broadly available technologies and supports the continued use of these technologies in international recreational firearm activities.
The changes will take effect November 20, 2026. Public comments on this interim final rule, posted to the Federal Register, will be accepted for 30 days, until August 24, 2026.
- The Department’s Directorate of Defense Trade Controls (DDTC) is continually working to benefit U.S. industry by helping American manufacturers compete in foreign markets alongside their foreign competitors.
- In consultation with its interagency partners, the Department assesses that firearm silencers, mufflers, and suppressors, other than those specially designed for fully automatic firearms, no longer provide a critical military or intelligence advantage, consistent with ITAR § 120.3 and Executive Order 14268.
- Under this rule, certain suppressors and other similar items will be added to the Commerce Control List (CCL), and BIS will require a license for certain exports, reexports, or in-country transfers of the newly controlled suppressors, including releases of related software and technology to foreign persons. License exceptions currently available for firearms will also be available for suppressors.
- These changes will have no effect on the possession, sale, or import of these items under the Department of Justice’s Bureau of Alcohol, Tobacco, and Firearms’ regulations.
- Silencers, mufflers, and sound suppressors specially designed for fully automatic firearms and fully automatic shotguns remain on the USML and will continue to be subject to Department controls under the ITAR.
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Removal from the U.S. Munitions List of Silencers, Mufflers, and Sound Suppressors for Non-Automatic and Semi-Automatic Firearms
July 22, 2026: 91 Fed. Reg. 46279: DDTC published an interim final rule removing silencers, mufflers, and sound suppressors for non-automatic and semi-automatic firearms up to .50 caliber from the International Traffic in Arms Regulations’ U.S. Munitions List (USML). A complementary rule by the Department of Commerce’s Bureau of Industry and Security will add these items to the Commerce Control List. Silencers, mufflers, and sound suppressors specially designed for fully automatic firearms up to .50 caliber and fully automatic shotguns will remain on the USML.
This rule is in furtherance of the President’s April 9, 2025, Executive Order 14268, “Reforming Foreign Defense Sales to Improve Speed and Accountability,” which directed the review of the USML to ensure that its control scope focused “on our most sensitive and sophisticated technologies.” The Department assessed that these items no longer provide a critical military or intelligence advantage.
This rule will take effect on November 20, 2026. The Department is seeking public comments on this rule for 30 days. Interested parties may submit comments by August 24, 2026 using one of the methods described in the interim final rule.
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U.S. Department of State Debars 14 Persons for Violating or Conspiring to Violate the Arms Export Control Act
July 27, 2026: 91 Fed. Reg. 46821: DDTC announced the debarment of 14 persons for violating or conspiring to violate the Arms Export Control Act. Under the terms of the statutory debarment, these persons are prohibited from participating directly or indirectly in any activities that are subject to the ITAR. Each person on this list will remain debarred until the Department approves an application request for reinstatement. All persons engaged in activities subject to the ITAR should be vigilant in their compliance with all export control regulations and ensure that their activities do not involve debarred persons.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=237f3595975e47500083b3b0f053afa9
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International Traffic in Arms Regulations: Modification of Civil Aircraft to Incorporate Aircraft Survivability Equipment.
July 27, 2026: DDTC is preparing to publish an interim final rule to amend the International Traffic in Arms Regulations (ITAR) to remove from the U.S. Munitions List (USML) items that no longer warrant inclusion and to exclude from the ITAR certain requirements for reexports, retransfers, and temporary imports.
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=1400-AG17
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International Traffic in Arms Regulations: Clarifying Policies of Denial, Updating the Major Non-NATO Ally List, and Minor Corrections
July 28, 2026: DDTC sent a final rule for interagency review that will amend the International Traffic in Arms Regulations (ITAR) to clarify certain policy-of-denial provisions, update country policies for Ethiopia, Iraq, and Somalia, add Saudi Arabia and Peru to the list of major non-NATO allies, and make minor, miscellaneous corrections.
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=1400-AG31
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30-Day Notice of Proposed Information Collection: Annual Brokering Report
July 29, 2026: 91 Fed. Reg. 47914: The Directorate of Defense Trade Controls (DDTC) is soliciting public comments to permit the evaluation of information collected in connection with the annual brokering report. DDTC will accept comments up to August 28, 2026.
In accordance with part 129 of the ITAR, U.S. and foreign persons required to register as a broker shall provide annually a report to DDTC enumerating and describing brokering activities, including all persons who participated in the activities, the quantity, description, and U.S. dollar value of the defense articles or defense services, the type and U.S. dollar value and source of any consideration received, and the DDTC number for the approval or the exemptions claimed. This information is currently used in the review of munitions export and brokering license applications and to ensure compliance with defense trade statutes and regulations. As appropriate, such information may be shared with other U.S. Government entities.
Brokering Reports are submitted annually with Statement of Registration renewals.
DDTC is soliciting public comments to permit the Department to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
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DDTC Name And Address Changes Posted To Website
July 1 through July 31, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Honeywell International Inc. spun off its Aerospace business to become a separate entity as follows:
- Previous Parent Entity: Honeywell International Inc. 855 S. Mint Street Charlotte, NC 28202, United States
New Parent Entity: Honeywell Aerospace Inc. 1944 E. Sky Harbor Circle, Phoenix, AZ 85034, United States
- Previous US Trading Name: Honeywell Aerospace Technologies 855 S. Mint Street Charlotte, NC 28202, United States
New U.S. Operating Company: Honeywell Aerospace US LLC 1944 E. Sky Harbor Circle, Phoenix, AZ 85034, United States
- Ultra PCS Limited and Ultra Electronics CEMS Limited changed their address as follows:
- From: Ultra PCS Limited Arle Court, Hatherley Lane Cheltenham, GL51 6PN
To: Ultra PCS Limited & Ultra Electronics CEMS Limited Brook Road Wimborne Dorset, BH21 2BJ United Kingdom
- From: Ultra Electronics CEMS Limited Waverley House, Hampshire Rd., Granby Industrial Estate Weymouth, DT4 9XD
To: Ultra PCS Limited & Ultra Electronics CEMS Limited Brook Road Wimborne Dorset, BH21 2BJ United Kingdom
- Aciturri Aeronáutica, S.L. and its subsidiaries changed its legal names as follows:
- Aciturri Aeronáutica, S.L. to Sonaca España Aeronáutica, S.L.
- Aciturri Aerostructures, S.L.U. to Sonaca Espana Aerostructures, S.L.U.
- Alestis Aerospace, S.L.U. to Sonaca Espana Aerospace, S.L.U.
- Aciturri Engineering, S.L.U. to Sonaca Espana Engineering, S.L.U.
- Goodrich Actuation Systems SAS changed its name to Safran Actuation Systems France
- Goodrich Actuation Systems Limited changed its name to Safran Actuation Systems Uk Ltd.
- Capella Space Corporation, 438 Shotwell Street, San Francisco, CA 94110 changed its address to 397 S Taylor Avenue, Louisville, CO 80027
- Spirent Communication PLC changed its name to Keysight Technologies (Spirent Service) Limited as a result of an acquisition.
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DDTC Final Commodity Jurisdiction Determinations Posted To Website
July 1, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between June 1, 2026 and June 30, 2026, on its website at:
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&kb_number=KB0011272
| Model Name | Manufacturer | Description | Final Determination | Final Determination Date |
| Skydio R10 Drone Part Numbers DR5E2KT2VR00000US (Two Drone Kit) and DR5ESKT2VR00000US (Single Drone Kit) and the Skydio C38 Controller, Part Number DR4ECTR200G0000JP | Skydio, Inc. | Compact quadcopter unmanned aerial vehicles (UAVs), and a wireless UAV controller | Seek a CCATS | 6/1/2026 |
| Collar, Part Number 20550467 | Lockheed Martin Corporation | Strain relief collar for a connector | USML Category XII(e)(1) | 6/1/2026 |
| SHARK Sensor Hub, Model SH 100 | Rugged Logic, Inc. | Ruggedized edge AI computing system | USML Category XI(b) | 6/1/2026 |
| Air-Breathing Ramjet Missile Mockup. Model 400B-010_Missile Cross-Team, Part Number 1727546 | Oerlikon AM US Inc. | Non-specific mockup used to demonstrate additive manufacturing applications | Seek a CCATS | 6/4/2026 |
| MAD Fuel System, Model: MAD-01 | Air Company Holdings, Inc. dba: AIRCO | A containerized fuel synthesis platform capable of producing JP-8, Jet A, and diesel fuel | Seek a CCATS | 6/4/2026 |
| Wolf Talk | Trident Systems LLC | An audio bridging and intercom system | Seek a CCATS | 6/4/2026 |
| Technical Proposal for Autonomous Aeriel Robotic Platform, as submitted | Artemis Smart Solutions LLC | Technical Proposal for an integrated printed circuit board | EAR99 | 6/4/2026 |
| HYT-172-00510 Piston Actuator | Riverbend Energetics MFG, LLC | Pyrotechnic-actuated piston | USML Category III(d)(11) | 6/9/2026 |
| Precision Wound Optical Cable Spools, Part Numbers 7090-2-2.8-5.6, 7053-2-3.75-5.2, 7034-2-4-5, 7260-4-8-9.5, and 7495-4-12.6-9.5 | Linden Photonics, Inc. | Packs of optical cable that deploy by being pulled from the inside end | Seek a CCATS | 6/15/2026 |
| Aspis Rucksack, Models Aspis 3 and Aspis 5 | System Technologies | Backpacks for small unmanned aerial vehicles | Seek a CCATS | 6/15/2026 |
| Advanced Battle Management Service | Monterey Technologies, Inc. | Proposed services in support of NATO’s Alliance Federated Surveillance and Control (AFSC) program | USML Category XI(d) | 6/23/2026 |
| Terrain Intelligence Engine (TIE) v1.0 | Aetherion Robotics LLC | Prototype system for predicting terrain conditions for autonomous platforms | Seek a CCATS | 6/23/2026 |
| .30-06 Springfield Blank Ammunition, Part Number OO-3006-BLK-1 | Orlando Ordnance, LLC | .30-06 Blank Ammunition | CCL ECCN 0A505.d | 6/23/2026 |
| M8, Model and Part Number: NFE004 | NFE Tactical LLC | reusable smoke grenade head | Seek a CCATS | 6/23/2026 |
| Simple Interface for GPS Health and Tracking (SIGHT), Model and Part Number SGTV2-XX | Navigation Technology Associates, Inc. | GPS receiver display | Seek a CCATS | 6/30/2026 |
| Flexible Coupling per AS7512, Model Number: 32J10, Part Number: 32J10-24A | Hydraflow | Fuel system coupling | Seek a CCATS | 6/30/2026 |
| DEW002 | Tactical Laser Defense Systems, Inc. | Handheld class IIIb laser designed to emit a controlled, expanded beam pattern for causing temporary optical interference with camera sensors | USML Category XVIII(a) | 6/30/2026 |
| Dagger Enterprise, Version 4.14.0 | The Johns Hopkins University – Applied Physics Lab | Suite of software applications | Dagger Service v4.14.0 – USML Category IX(b)(4)(iii) Dagger Application v4.14.0 – USML Category IX(e)(1) Dagger Web Application v.15.7 – USML Category IX(e)(1) | 6/30/2026 |
| Incident Response Diode (IRD), Model IRD 1.0 | Owl Cyber Defense Solutions, LLC | USB device that provides a security barrier between a computer and an untrusted device during data transfer | Seek a CCATS | 6/30/2026 |
| StratoDrop, Model SD-10 v2 | In Orbit Aerospace Inc. | High Altitude unmanned aerial system that uses a paraglider for lift and guidance | Seek a CCATS | 6/30/2026 |
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
- Kingdom of Saudi Arabia – Advanced Precision Kill Weapon Systems
- Kuwait – C-17 Sustainment
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/07/kuwait-c-17-sustainment/
- Greece – Switchblade 300 Block 20 Lethal Miniature Aerial Missile System
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Department of Commerce – Bureau of Industry and Security
Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations
July 10, 2026: 91 Fed. Reg. 43034: The Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will significantly upgrade the status of the United Arab Emirates (UAE) under the Export Administration Regulations (EAR) (15 CFR parts 730-774) in recognition of the UAE’s status as a U.S. Major Defense Partner and its support in advancing U.S. national security interests, including Operation Epic Fury.
BIS removed the UAE from EAR Country Groups D:3 and D:4, which among other things, eliminated restrictions on support for the UAE’s unmanned aerial vehicle programs. At the same time, BIS reclassified the UAE as EAR Country Group A:5. This provides the UAE Government and approved commercial entities with eligibility for license-free exports, reexports, and in-country transfers under License Exception Strategic Trade Authorization (STA) of Commerce-controlled military items; certain commercial satellites and spacecraft; and dual-use items useful in oil and gas production, desalination, civil nuclear power generation, and/or other items available to Country Group A:5 destinations license-free. License-free exports, reexports, and in-country transfers of these items under STA will support key UAE commercial and infrastructure needs and better equip the UAE defense establishment to support U.S. interests in the Middle East. This special status under the EAR is warranted in light of the ongoing U.S.-UAE military partnership and the UAE’s commitment to preventing the diversion and misuse of sensitive U.S. technology.
In addition, consistent with the U.S.-UAE Artificial Intelligence Cooperation framework signed in May 2025, Commerce is approving the UAE Government and certain companies to receive advanced computing items in the UAE license-free, including AI chips and servers. The UAE has reaffirmed its commitment to the investment commitments in the framework, including the commitment to make matching investments in U.S. AI digital infrastructure buildout.
https://www.bis.gov/press-release/department-commerce-eases-export-controls-uae
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Implementation of EAR Export Controls on Silencers, Mufflers, and Sound Suppressors; and Other Firearms Related Changes
July 22, 2026: 91 Fed. Reg, 46252: BIS published an Interim Final Rule (IFR) alongside the complementary State IFR implementing State’s removal of certain sound suppressors for firearms and shotguns from the USML under the ITAR. As specified in the IFR, the sound suppressors removed from the USML by the State IFR will be controlled on the CCL and enumerated under new item paragraph 0A501.f in ECCN 0A501 and item paragraph 0A502.f in ECCN 0A502. Items controlled under ECCN 0A501.f are sound suppressors capable of being used with rifles controlled under ECCNs 0A501 or 0A506, pistols controlled under ECCNs 0A501 or 0A507, or certain sound suppressors capable of being used interchangeably with any combination of rifles, pistols, and shotguns. Sound suppressors that are for exclusive use with shotguns controlled under ECCNs 0A502 or 0A508 are enumerated under ECCN 0A502.f. BIS has also moved the items formerly identified in the header of ECCN 0A502 into item paragraphs within the ECCN.
BIS will require an authorization to export, reexport, or transfer (in-country) sound suppressors that are being added to the CCL, including releases of related technology and software controlled on the CCL, to foreign persons in the United States or abroad.
This rule is effective November 20, 2026, except for amendatory instructions 1, 2, 3, 4, 6, 7, 8, 9, 10, and 11, which are effective July 23, 2026. Details of the IFR can be found at the following link.
https://www.govinfo.gov/content/pkg/FR-2026-07-23/pdf/2026-14942.pdf
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Department of Commerce Issues a Press Release re Streamlining Export Controls for Sound Suppressors
July 27, 2026: BIS announced that, as of November 20, 2026, the export of certain silencers, mufflers, and sound suppressors is subject to BIS’s Export Administration Regulations, rather than the State Departments U.S. Munitions List. This deregulatory action aligns export controls on suppressors with the controls already applied to firearms.
Under this rule, suppressors will be added to the Commerce Control List (CCL), and BIS will require a license for certain exports, reexports, or in-country transfers of the newly controlled suppressors, including releases of related software and technology to foreign persons. License exceptions currently available for firearms will also be available for suppressors.
“This deregulatory action on suppressors is a common-sense move that alleviates the compliance burden on America’s proud firearms industry, while continuing to protect national security,” said Jeffrey I. Kessler, Under Secretary of Commerce for Industry and Security.
issued a press release
https://www.bis.gov/press-release/department-commerce-streamlines-export-controls-sound-suppressors
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
Massachusetts Man Convicted of Violating U.S. Sanctions Against Iran
July 14, 2026: A Massachusetts man was convicted in federal court in Boston following a 14-day jury trial for charges related to a scheme to illegally export sophisticated electronic components from the United States to Iran.
Mahdi Mohammad Sadeghi, 43, a dual U.S.-Iranian national of Natick, Massachusetts, was convicted of one count of conspiracy to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR); and two counts of violation of the IEEPA and the ITSR.
The defendant was charged by criminal complaint in December 2024 alongside Mohammad Abedininajafabadi, also known as Mohammad Abedini (Abedini), of Tehran, Iran, and subsequently indicted by a federal grand jury shortly thereafter. They were again charged in a superseding indictment in December 2025. Abedini remains a fugitive in wanted status.
Abedini is the founder and managing director of an Iranian company, San’at Danesh Rahpooyan Aflak Co. (SDRA or SADRA), that manufactures navigation modules used in the IRGC’s military drone program. SDRA’s main business is the sale of a proprietary navigation system—known as the Sepehr Navigation System—to the IRGC, which the United States designated as a foreign terrorist organization (FTO) on April 15, 2019. The primary application of SDRA’s Sepehr Navigation System is for use in Unmanned Aerial Vehicle (UAVs) – also known as drones – as well as cruise and ballistic missiles.
Sadeghi was employed by a Massachusetts-based microelectronics manufacturer (U.S. Company 1) and was one of the founders of a Massachusetts-based technology company (U.S. Company 2) that specializes in wearable sensors that provide kinetic monitoring for fitness applications.
Sadeghi and, allegedly, Abedini and others conspired to evade U.S. export control and sanctions laws by procuring U.S. origin goods from, U.S. Company 1 and causing them to be exported and supplied to Iran and, in particular, Abedini’s Iranian company, SDRA.
In or around 2016, Sadeghi traveled to Iran to request funding for U.S. Company 2 from the Iranian National Elites Foundation (INEF), which is an Iranian governmental organization whose main purpose is to recognize, organize and support Iran’s elite national talents. In exchange for funding for U.S. Company 2, which Sadeghi’s company ultimately received from the INEF, Sadeghi and others created a second company in Iran (Iranian Company 1). Shortly after forming Iranian Company 1, Sadeghi, through Iranian Company 1, entered into a contract with SDRA for the purchase of SDRA’s technology. On multiple occasions beginning in or around 2016, Sadeghi helped Abedini procure U.S. export-controlled electronic components for reexport to Iran.
Due to U.S. laws restricting exports to Iran, Abedini established a Switzerland front company for SDRA, Illumove SA (Illumove). According to court documents, with Sadeghi’s assistance, Abedini, through Illumove, entered into a contract with U.S. Company 1 to develop a product to evaluate U.S. Company 1’s electronic components, including sophisticated semiconductors. Sadeghi caused U.S.-origin goods to be transferred to Iran, through Illumove, for the benefit of SDRA, including accelerometers, gyroscopes, and inertial measurement units. Certain of the electronic components that Abedini allegedly obtained through Illumove were the same types of electronic components used in SDRA’s Sepehr Navigation System.
Abedini also allegedly provided material support to a foreign terrorist organization, the IRGC Aerospace Force, which is a strategic missile, air and space force. Since at least in or about 2014, SDRA has had multiple projects with the IRGC Aerospace Force, including projects for guided rockets and integrated navigation systems. As alleged, between 2021 and 2022, approximately 99% of SDRA’s sales of the Sepehr Navigation System, which are used in IRGC one-way attack drones, were to the IRGC’s Aerospace Force.
“By illegally exporting sophisticated American technology to Iran, Sadeghi violated U.S. laws and endangered national security,” said Assistant Director Roman Rozhavsky of the FBI Counterintelligence and Espionage Division. “This conviction holds him accountable. The FBI and our partners are committed to using all our resources to bring to justice anyone who helps our adversaries.”
On Jan. 28, 2024, three U.S. service members were killed, and more than 40 others were injured, in a drone attack by IRGC-backed militants on a military base located in northern Jordan, known as Tower 22. According to court documents, analysis of the drone that was recovered from the site of the attack showed that the drone was an Iranian Shahed UAV and that the navigation system used in the drone was manufactured by Abedini’s company.
The charges of violation of the IEEPA and the ITSR, and conspiracy to do so, each provide for a sentence of up to 20 years in prison, three years of supervised release and a fine of up to $1 million fine. Sentences are imposed by a federal district court judge based upon the U.S. Sentencing Guidelines and statutes which govern the determination of a sentence in a criminal case.
https://www.justice.gov/opa/pr/massachusetts-man-convicted-violating-us-sanctions-against-iran
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The Boeing Company Settles Antiboycott Violations
July 31, 2026: The Office of Antiboycott Compliance (OAC), the Bureau of Industry and Security (BIS) published the settlement agreement with The Boeing Company (Boeing) for violations of the anti-boycott provisions of the Export Administration Regulations. Boeing agreed to pay a civil penalty of $41,000 for two violations of the regulations.
Boeing voluntarily disclosed to OAC two incidents that occurred in October and November of 2019 involving the company’s intent to comply with, further, or support an unsanctioned foreign boycott, furnished two items of information concerning Boeing’s or another person’s past, present or proposed business relationships with or in a boycotted country or with another person who is known or believed to be restricted from having any business relationship with or in a boycotting country.
In 2019, Boeing furnished to a U.S. trade show logistics provider two items of information in combined commercial invoices/packing lists concerning Boeing’s past, present or proposed business relationships with or in a boycotted country or with another person who is known or believed to be restricted from having any business relationship with or in a boycotting country in violation of 15 C.F.R. § 760.2(d).
Specifically, Boeing participated in the Dubai Airshow in the United Arab Emirates in November 2019. In connection with temporary exports of Boeing models and office supplies for the air show, a Boeing employee downloaded from a U.S. trade show logistics provider’s website (and subsequently completed on behalf of Boeing) a combined commercial invoice/packing list template containing the following prohibited boycott language:
- “We certify that no labor, capital, parts or raw materials of Israeli origin have been used in the printing, publishing or manufacture of these goods and [that] none are part or parent companies of firms included on the Israeli Boycott Blacklist…”; and
- “[We certify that] none are part or parent companies of firms included on the Israeli boycott blacklist.”
The proposed charging letter, the order and settlement agreement are found at:
https://www.bis.gov/media/documents/a781.pdf
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for July 1 through July 31, 2026.
- Counter Narcotics Designations; Counter Terrorism Designations and Designation Update
https://ofac.treasury.gov/recent-actions/20260701
- Treasury Sanctions Brazilian Criminal Network Exploiting U.S. Financial System to Launder Drug Proceeds
https://home.treasury.gov/news/press-releases/sb0549
- Terrorist Designation of Chone Killers
- Reminder to File the 2026 Annual Report of Blocked Property
https://ofac.treasury.gov/recent-actions/20260701_33
- Issuance of Amended Iran-related General License
https://ofac.treasury.gov/recent-actions/20260707
- Issuance of Amended Russia-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260708
- Issuance of Democratic Republic of the Congo-related General License
https://ofac.treasury.gov/recent-actions/20260710
- Iran-related and Counter Terrorism Designations; Issuance of Iran-related General License
https://ofac.treasury.gov/recent-actions/20260710_33
- Treasury Targets Key Supreme Leader Financier and Iran’s Shadow Exchange Houses
https://home.treasury.gov/news/press-releases/sb0558
- Cyber-related Designations; Cuba Designations; Issuance of Cuba-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260713
- Treasury Sanctions Malware and Infrastructure Providers Supporting Ransomware Attacks Against Americans
https://home.treasury.gov/news/press-releases/sb0559
- Further Sanctions on the Cuban Regime’s Sources of Funding and Tools of Oppression
- Non-Proliferation Designations; Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260715
- Treasury Targets Global Network Procuring Weapons for Iranian Regime
https://home.treasury.gov/news/press-releases/sb0564
- Hong Kong-related Designations Updates and Removals
https://ofac.treasury.gov/recent-actions/20260717
- Issuance of Venezuela-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260717_33
- Russia-related Designations Updates
https://ofac.treasury.gov/recent-actions/20260720
- Counter Terrorism Designations; Counter Narcotics Designations; Cuba Designations; Belarus-related Designation Removal; Issuance of Cuba-related General Licenses
https://ofac.treasury.gov/recent-actions/20260723
- Treasury Disrupts Muslim Brotherhood and Hamas Financial Networks
https://home.treasury.gov/news/press-releases/sb0572
- Treasury Takes Largest Action Ever Targeting Cartel de Jalisco Nueva Generacion
https://home.treasury.gov/news/press-releases/sb0573
- Additional Sanctions Designations Targeting the Corrupt Cuban Communist Regime and its Financial Backers
- Iran-related Designations; Issuance of Amended Russia-related General License and Frequently Asked Questions; Issuance of Amended Venezuela-related Frequently Asked Question; Publication of Regulatory Amendments
https://ofac.treasury.gov/recent-actions/20260724
- Sanctions List Removals; Sanctions List Updates
https://ofac.treasury.gov/recent-actions/20260727
- Iran-Related Designations
https://ofac.treasury.gov/recent-actions/20260729
- Counter Terrorism Designations; Non-Proliferation Designation Update
https://ofac.treasury.gov/recent-actions/20260730
- Treasury Cracks Down on Global Networks Enabling Iran’s Mahan Air and IRGC