This newsletter is a listing of the latest changes in export control regulations through May 31, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
President
Imposing Sanctions On Those Responsible For Repression In Cuba And For Threats To United States National Security And Foreign Policy
May 1, 2026: 91 Fed. Reg. 25061: The President issued Executive Order 14004 Imposing Sanctions On Those Responsible For Repression In Cuba And For Threats To United States National Security And Foreign Policy. This E.O. imposes sanctions on foreign persons or entities determined by the Secretary of State, in consultation with the Secretary of the Treasury; or by the Secretary of the Treasury, in consultation with the Secretary of State:
- to operate in or have operated in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, or any other sector of the Cuban economy, as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State;
- to be owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
- to own or control, directly or indirectly, any person whose property or interests in property are blocked pursuant to this order;
- to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba or any person whose property or interests in property are blocked pursuant to this order;
- to be or have been a leader, official, senior executive officer, or member of the board of directors of the Government of Cuba or an entity whose property or interests in property are blocked pursuant to this order;
- to be a political subdivision, agency, or instrumentality of the Government of Cuba;
- to be responsible for or complicit in, or to have directly or indirectly engaged in or attempted to engage in, serious human rights abuse in Cuba;
- to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, corruption related to Cuba, including corruption by, on behalf of, or otherwise related to the Government of Cuba, or a current or former official at any level of the Government of Cuba, such as the misappropriation of public assets, expropriation of private assets for personal gain or political purposes, or bribery; or
- to be an adult family member of a person designated pursuant to this order.
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Department of State, Directorate of Defense Trade Controls (DDTC)
ITAR Ethiopia Licensing Policy Change
May 11, 2026: The Directorate of Defense Trade Controls (DDTC) posted to its website that the U.S. has terminated the arms embargo on Ethiopia. Accordingly, DDTC has removed the policy of denial for Ethiopia and is now reviewing license applications for ITAR-controlled activities involving Ethiopia on a case-by-case basis.
A forthcoming regulatory change will remove Ethiopia from the list of countries in ITAR § 126.1.
https://www.pmddtc.state.gov/ddtc_public
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End-Use Monitoring Report for FY 2025
May 26, 2026: The Directorate of Defense Trade Controls (DDTC) released its Blue Lantern and Golden Sentry, End-Use Monitoring (EUM) reports for FY2025.
The Blue Lantern program’s mission is to help ensure the security and integrity of U.S. defense trade through direct commercial sales. The program is designed to support U.S. interests by minimizing the risk of diversion and unauthorized use of U.S. defense articles or defense services to countries and other parties that aim to harm the U.S. and its allies. It combats illicit arms trafficking, uncovers security problems that can then be mitigated, and builds confidence and cooperation among defense trade partners.
Of interest:
- DTC adjudicated over 26,500 export authorization requests. Country and End-Use Analysis Division (CEA) initiated Blue Lantern checks on over 390 export authorizations or authorization requests in 82 countries.
- Several Blue Lantern checks were used to not only review specific transactions but to also analyze the management structure and security controls of foreign companies that might pose a risk of diversion of defense articles due to their acquisition or investment by a suspect foreign entity.
- CEA closed Blue Lantern checks on over 350 export authorizations or requests in FY 2025.
- 72 percent of the checks reported “favorable” results.
- 27 percent of the checks were closed as “unfavorable.”
- 1 percent of the checks were closed as “no action” due to logistical constraints that prevented Post from completing a check or changes to the original license request obviating the need for a check.
- Reasons for Unfavorable Outcome (Count).
- 55 – Refusal to cooperate
- 34 – Multiple Reasons
- 29 – Derogatory information/unreliable foreign party
- 21 – Other
- 20 – Unable to confirm order or receipt of goods
- 9 – Inability to confirm existence of foreign party
- 6 – Unauthorized reexport/retransfer
- 5 – Lack of secure storage facilities
The Golden Sentry gram EUM program is designed to provide reasonable assurance, to the extent practicable, that the recipient of goods and services received through the Foreign Military Sales program is complying with the requirements imposed by the U.S. Government with respect to the use, transfer, and security of defense articles and defense services, and that such articles and services are being used for the purposes for which they were provided.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=f7c320619774cb14fe5c39b0f053af72
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=fbc320619774cb14fe5c39b0f053af77
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May 26, 2026: DDTC published on its website the 2025 Section 655 Report. This report documents defense articles and defense services licensed for permanent export under Section 38 of the Arms Export Control Act (AECA), 22 U.S.C. 2778, to each foreign country and international organization during fiscal year (FY) 2025, in response to the requirements of Section 655(b)(3) of the Foreign Assistance Act (FAA) of 1961, as amended. Section 655(b)(3) also requires the specification of certain semiautomatic assault weapons and their spare parts, which are under the jurisdiction of the U.S. Department of Commerce; the Department of Commerce will submit a separate report regarding these items. Additionally, the U.S. Department of War will provide a separate report on International Military Education and Training activities.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=2d6361521b414b108e3086eae54bcb58
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=a56365521b414b108e3086eae54bcb72
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60-Day Notice of Proposed Information Collection: Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data
May 28, 2026: 91 Fed. Reg. 31817: The Department of State (DOS) is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, DOS is requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collection to OMB.
In accordance with part 123 of the International Traffic in Arms Regulations (ITAR), any person who intends to permanently export, temporarily export, or temporarily import classified defense articles, including classified technical data must first obtain Directorate of Defense Trade Controls authorization. The “Application for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data” (Form DSP-85) is used to obtain permission for the permanent export, temporary export, or temporary import of classified defense articles, including classified technical data, covered by the U.S. Munitions List (USML). This form is an application that, when completed and approved by the Bureau of Political Military Affairs, Directorate of Defense Trade Controls (PM/DDTC), Department of State, constitutes the official record and authorization for all classified commercial defense trade transactions, pursuant to the Arms Export Control Act and the ITAR.
DOS is soliciting public comments to permit the DOS to:
- Evaluate whether the proposed information collection is necessary for the proper functions of the Department.
- Evaluate the accuracy of our estimate of the time and cost burden for this proposed collection, including the validity of the methodology and assumptions used.
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the reporting burden on those who are to respond, including the use of automated collection techniques or other forms of information technology.
Please note that comments submitted in response to this Notice are public record. Before including any detailed personal information, you should be aware that your comments as submitted, including your personal information, will be available for public review.
The DOS will accept comments from the public up to July 27, 2026.
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DDTC Name And Address Changes Posted To Website
May 1 through May 30, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
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- Sopra Steria India Limited changed its address from Seaview Special Economic Zone, Building 4, Plot No. 20 & 21, Sector-135 Noida, Gautam Buddha Nagar, U.P. 201304, India to Institutional Plot No. B-9, Sector 132, Noida, 201304, India.
- A DSV Air & Sea Inc. entity changed its name and location due to a corporate restructuring as follows
- From: Schenker Seino Co. Ltd. located at 15/16 Tennoz Central Tower, 2-24 Higashi-Shinagawa, 2-chome 140-0002 Tokyo Japan
To: DSV Air & Sea Co. Ltd. located at 3F, 2-5-4, Fukuzumi 135-0032 Koto-Ku, Tokyo Japan
- Keysight Technologies Belgium BV changed it address from: Wingepark 51, Rotselaar, VB B-3110, Belgium to Diestsevest 32, Unit 2B, Leuven, Flemish Brabant, 3000 Belgium.
- Wytwornia Sprzetu Komunikacyjnego “PZL-Swidnik” Spolka Akcyjna changed its name to Leonardo PZL-Swidnik Spolka Akcyjna as a result of a corporate restructuring.
- Honeywell International Inc. subsidiaries that fall within Honeywell Aerospace changed their name and address as follows:
- From: Honeywell International (India) Private Limited – 1121-21, 11ith Floor, Tower A, DLF Tower, Jasola, Jasola District Centre, Delhi, New Delhi, 110025, India
To: Honeywell Aerospace India Private Limited – Campus 5A, RMZ Eco World, Marathahalli Outer Ring Road, Devarabeesanahalli, Bengaluru Urban-560102, Bengaluru, Karnataka, India
- From: Honeywell Technology Solutions Lab Pvt. Ltd. – Survey # 96 & 97 Boganahalli Village, Bangalore East, Survey#72/2 & 75/5, Doddakananahalli Village, Varthur Hobli, Karnataka, Bangalore 560 103, India
To: Honeywell Aerospace India Private Limited – Campus 5A, RMZ Eco World, Marathahalli Outer Ring Road, Devarabeesanahalli, Bengaluru Urban-560102, Bengaluru, Karnataka, India - From: Honeywell Technology Solutions Qatar – 5th Floor Amwal Tower, Dafna 61, Al Wahda Street 391, P.O. Box 63757, Doha, Qatar
To: Honeywell Aerospace Services Middle East – Office No. 1021, 10th Floor, Al Shoumoukh Tower B, Building No. 58, Suhaim bin Hamad Street, Doha, Qatar
- From: Honeywell Turki-Arabia Limited – Khobar 31952, Dhahran Techno Valley, PO Box 31916, Dhahran, Saudi Arabia
To: Honeywell Aerospace Saudi Arabia – Building No. 7682, District No. 2570, Riyadh, 13322, Saudi Arabia - From: Honeywell Middle East FZE – Office No. LB15413, P O Box 18530 Jebel Ali Free Zone, Dubai, United Arab Emirates
To: Honeywell Aerospace General Trading LLC – SOC Office 208-96, Dubai Supreme Court Complex, Umm Hurair 2, Dubai, United Arab Emirates - From: Honeywell Middle East Limited – Plot No. J-05, Honeywell Building, Abu Dhabi, Masdar, United Arab Emirates
To: Honeywell Aerospace General Trading LLC – SOC Office 208-96, Dubai Supreme Court Complex, Umm Hurair 2, Dubai, United Arab Emirates - From: Honeywell International Middle East Limited – Building 2 Level 1, Emaar Business Park Dubai, 232362 United Arab Emirates
- To: Honeywell Aerospace General Trading LLC – SOC Office 208-96, Dubai Supreme Court Complex, Umm Hurair 2, Dubai, United Arab Emirates
- ALTEN GMBH, located at Rosenauer Straβe 27, 96450 Coburg, Germany changed its address to Frankfurter Ring 81, 80807 Munich, Germany.
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Bureau of Political-Military Affairs – Foreign Military Arms Sales
BPMA Notified Congress of Potential FMS Sales to the following Countries:
Details regarding each case can be found at the links below.
- Israel – Advanced Precision Kill Weapon System
- Philippines – Bell 505 Jet Ranger X Helicopter
- Ukraine – Joint Direct Attack Munitions – Extended Range
- Canada – C-17 Sustainment
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/05/canada-c-17-sustainment/
- Belgium – AGM-184 Joint Strike Missiles
- India – Apache Helicopters Follow-on Support
- India – Sustainment Support for M777A2 Ultra-Light Howitzers
- Republic of Korea – AH-64E Apache Upgrade Program
- Republic of Korea – MH-60R Multi-Mission Helicopters
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/05/republic-of-korea-mh-60r-multi-mission-helicopters/ - Ukraine – Hawk Missile System Sustainment
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Department of Commerce – Bureau of Industry and Security (BIS)
Guidance Regarding Enforcement of License Requirements for Advanced Computing Items for Entities Headquartered in Country Group D:5 and Macau
May 31, 2026: The Department of Commerce, Bureau of Industry and Security (BIS) issued guidance to clarify that a license is required to export advanced computing items to entities headquartered in Country Group D:5 (see supplement no. 1 to part 740 of the Export Administration Regulations (EAR) (15 CFR parts 730-774)) or Macau or with an ultimate parent company headquartered in Country Group D:5 or Macau – even if the entities themselves are located outside Country Group D:5 or Macau.
This license requirement was first introduced on November 17, 2023. It was implemented via an end-user control in § 744.23(a)(3) of the EAR and applied to all advanced computing items (e.g., those specified in Export Control Classification Numbers (ECCNs) 3A090.a and .b, 4A090.a and .b, and related .z paragraph items). In January 2025, the AI Diffusion Rule transferred the requirement for these “.a” items from § 744.23(a) into § 742.6 as part of a new worldwide license requirement. In May 2025, BIS announced that it would not be enforcing the AI Diffusion Rule’s new compliance requirements.
Recently, BIS has received questions as to whether the preexisting license requirement established in November 2023 is still being enforced for “.a” advanced computing items to Country Group D:5 and Macau-headquartered entities located outside of destinations that were subject to a license requirement prior to the AI Diffusion Rule. The answer is yes. Specifically, a license requirement continues to apply under § 742.6(a)(6)(iii)(A) of the EAR to all destinations outside the United States for these advanced computing items when such items are for entities headquartered in, or whose ultimate parent company is headquartered in, Country Group D:5 or Macau. Because this license requirement predates the AI Diffusion Rule, BIS’s non-enforcement policy with respect to the destination-based license requirements for these advanced computing items under § 742.6(a)(6)(iii)(A) applies only to the extent such items are not for entities headquartered in or that have ultimate parent companies headquartered in Country Group D:5 or Macau. Exporters should continue to seek BIS licenses for such transactions, unless a license exception specified in § 740.2(a)(9)(ii) is available.
Bona fide operators of data centers who are otherwise engaged in activities consistent with the EAR are not required to cease the ongoing use, storage, disposal, or servicing of advanced computing items because of this guidance, until further notice from BIS.
For information regarding the submission of voluntary self-disclosures, see Section 764.5 of the EAR. For guidance on the submission of license applications, see part 748 of the EAR.
https://www.bis.gov/media/documents/bis-guidance-may-31-2026.pdf
Department of Commerce – Census Bureau
Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions; Correction
May 26, 2026: 91 Fed. Reg. 30485: On August 14, 2025, the Bureau of the Census (Census Bureau) published a final rule in the Federal Register entitled “Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions”, which became effective on September 15, 2025. Subsequent review of the final rule in the Code of Federal Regulations identified errors necessitating corrective action. Accordingly, this final rule issues non-substantive corrections to the FTR.
First, this action corrects Section 30.3(a). Due to a publication error, Section 30.3(a) contains duplicative text that is already identified in the subparagraphs of that section. Second, this action corrects Section 30.6(b)(13). Due to an oversight, the text “consumption or” was inadvertently included in the second sentence during the rule writing process.
Accordingly, for the reasons stated above, 15 CFR part 30 is corrected by making the following correcting amendment:
- The authority citation for 15 CFR part 30 continues to read as follows:
Authority: 5 U.S.C. 301; 13 U.S.C. 301-307; Reorganization plan No. 5 of 1990 (3 CFR 1949-1953 Comp., p.1004); Department of Commerce Organization Order No. 35-2A, July 22, 1987, as amended and No. 35-2B, December 20, 1996, as amended; Public Law 107-228, 116 Stat. 1350.
- Amend § 30.3 by revising paragraph (a) to read as follows:
- 30.3 Electronic Export Information filer requirements, parties to export transactions, and responsibilities of parties to export transactions.
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(a) General filer requirements.
(1) The filer of EEI for export transactions is either the USPPI or the authorized agent. If a foreign entity is the USPPI, they are prohibited from filing the EEI and must authorize an agent to file on their behalf.
(2) The filer shall maintain a physical office or residence in the United States, be physically located in the United States at the time of preparing and filing the EEI, and have an EIN or DUNS and be certified to report in the AES. If the filer does not have an EIN or DUNS, the filer must obtain an EIN from the Internal Revenue Service.
(3) All EEI submitted to the AES shall be complete, accurate, and timely. The filer is responsible for ensuring that the EEI is complete, accurate, and timely, except insofar as that party can demonstrate that it reasonably relied on information based on personal knowledge of the facts and information furnished by other responsible persons participating in the transaction. All parties involved in export transactions, including authorized agents, should be aware that invoices and other commercial documents may not necessarily contain all the information needed to prepare and file the EEI.
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- Amend § 30.6 by revising paragraph (b)(13) to read as follows:
- 30.6 Electronic Export Information data elements.
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(b) * * *
(13) Entry number. The entry number must be reported when goods of foreign origin enter the United States for warehousing (entered into a bonded warehouse) or are admitted into a FTZ before being exported. For goods that are exported after entering the United States for warehousing, the 11-position entry number as identified on the CBP-7501 shall be reported. For goods that are exported from a FTZ, the 9-digit inbond serial number associated with the removal shall be reported. For all other scenarios where goods are exported after entering the United States for consumption, the 11-position entry number as identified on the CBP-7501 may be reported. When the importer of record on the import entry is the customs broker or foreign person, the customs broker shall provide the entry number to assist in the preparation of the EEI (See 15 CFR 30.3(b)(2) and the Note to paragraph § 30.3(b)(2)(iv)).
Department of Justice – Bureau of Alcohol Tobacco, Firearms and Explosives (BATFE)
Update to Proscribed Countries for Import Restrictions
May 6, 2026: 91 Fed. Reg. 24387: BATFE published a proposed rule to amend Department of Justice (‘‘Department’’) regulations to remove the existing, outdated list of proscribed countries from which ATF denies applications to permanently import defense articles and services and update it to reference a Department of State list of proscribed countries. The rule also proposes to remove the list of former Soviet countries from which ATF currently denies applications to permanently import most firearms and ammunition, leaving only the Russian Federation as the proscribed country of origin for these imports.
This rule proposes to remove the current content of ATF’s regulations at 27 CFR 447.52(a) and replace it with a general statement of the U.S. policy on restricting imports from certain countries that would inform the public that ATF will base its arms import decisions on the Department of State’s policies and lists in 22 CFR 126.1. This change would ensure that the list of proscribed countries and conditions will remain consistent across Departments. It will also better inform importers of defense articles under the AECA and help ensure consistent application of foreign policy.
This rule also proposes to amend 27 CFR 447.52(b), which provides a list of countries for which all applications to permanently import firearms and ammunition manufactured or located in those countries must be denied (except for certain specifically exempted firearm models). The current list, which was added to the regulation in 1997, reflects a Department of State policy adopted after the United States entered into a Voluntary Restraint Agreement (‘‘VRA’’) with the Russian Federation in 1996. The list comprises the Russian Federation and the former Soviet countries of Georgia, Kazakhstan, Kyrgyzstan, Moldova, Turkmenistan, Ukraine, and Uzbekistan.
Thirty years later, this policy—and, by extension, the list in 447.52(b)(1)— reflects outdated trade and security concerns. Lifting these restrictions will ensure consistency with current U.S. foreign policy as directed by the Department of State, see 22 CFR 126.1(a), and allow ATF to transition from a policy of denying all requests to import firearms from certain countries to a policy that permits ATF to review license applications on a case-by-case basis. Additionally, as the terms of the VRA remain in effect, ATF will continue to restrict certain firearms and ammunition imports from the Russian Federation.
Comments must be submitted in writing on or before (or, if mailed, must be postmarked on or before) July 6, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
https://www.govinfo.gov/content/pkg/FR-2026-05-06/pdf/2026-08911.pdf
Importing Training Rounds
May 6, 2026: 91 Fed Reg 24400: BATFE published a proposed rule to amend Department of Justice (“Department”) regulations to clarify that certain training rounds do not meet the definition of “ammunition” as defined by the Gun Control Act and are not regulated by the Arms Export Control Act (“AECA”) . Less-than-lethal ammunition, which is distinct from training rounds, will still generally be considered ammunition.
BATFE’s proposal clarifies that training rounds are not “ammunition” because they are not designed to be fired from a “firearm,” as defined by the Gun Control act of 1968 (“GCA”). Although training rounds consist of cartridge cases, primers, propellant powder, and projectiles, they are not “designed for use in any firearm.”
As applicable here, the definition of “firearm” includes “any weapon (including a starter gun) which will or is designed to or may readily be converted to expel a projectile by the action of an explosive.” Although “weapon” is not further defined by the GCA or AECA, the Supreme Court in Bondi v. VanDerStok, explained that the GCA’s definition of “firearm” demonstrates congressional intent to regulate inoperable firearms and firearms capable of being readily converted to expel a projectile by the action of an explosive. The Court highlighted that the statute indicates that a starter gun is a weapon prior to any attempted conversion. Additionally, the Court explained that a “weapon,” as it pertains to the definition of firearms, is “an instrument of offensive or defensive combat.” As discussed below, training rounds are designed for use in, and are fired from, training guns, which are not “firearms” within the meaning of the GCA.
First, unlike starter guns, Congress did not expressly regulate training guns as weapons under 18 U.S.C. 921(a)(3). Moreover, training guns, unlike starter guns, are generally not capable of being readily converted to expel a projectile by the action of an explosive. Under these two aspects of the definition, training guns do not fall within the definition of “firearm.”
Second, training guns as assembled are not weapons designed for offensive or defensive combat because they are incapable of firing conventional firearm ammunition. The conversion kits used in a training gun are specifically designed so that the gun can function only with a training round that has significantly less propellant powder than conventional firearm ammunition, which allows the training round to safely and effectively cycle the conversion kit bolt. Using conventional firearm ammunition in a training gun would be unsafe. Thus, training guns are designed with additional safety features including offset firing pins to ensure they can fire only training rounds in specific calibers. In other words, the devices that fire training rounds are not “firearms” within the meaning of the GCA or the AECA.
Additionally, with respect to the training round itself, the cartridges, when discharged, produce low-energy projectiles that are designed to provide immediate feedback to a trainee during a military or law enforcement training exercise. The projectiles provide impact awareness for the shooter by providing imprint markings on the target or provide immediate non-lethal feedback to a user in close-range reality-based training scenarios often leaving bruising or welts on a person. These projectiles are not intended to cause death or serious bodily injury, nor will they likely cause such injury when used with proper safety equipment. Because they are low-energy, the projectiles are also ineffective as “less-than-lethal” ammunition in riot control situations, unlike bean bag rounds and rubber pellets that are used in weapons for nonlethal riot control. Given that these training rounds are not useful for offensive or defensive combat, they are not designed for use in instruments of offensive or defensive combat.
Moreover, based on the design of the cartridge, the training rounds themselves typically have design features consistent with use in a training device and not for use in unmodified firearms. For example, a training round for a 9mm training pistol or AR-type training rifle (or device with a conversion kit) has insufficient propellant powder to cycle a firearm’s slide or bolt. The training rounds are also not reloadable, i.e., they cannot be altered to be lethal or less-than-lethal ammunition. The cartridge case of each training round contains a plastic piston that, when removed, weakens and damages the casing so the training round cannot be reloaded without being destroyed. Nevertheless, if a manufacturer makes a “training round” that is designed for use only in a firearm, then the round may be ammunition. ATF notes that an item marketed or advertised as a “training round” would not by itself make it exempt from regulation as “ammunition.” Rather, ATF must make a determination based on an examination of the item that the round is not designed for use in offensive or defensive combat and in a firearm.
Accordingly, ATF proposes to amend the definition of “ammunition” by adding a new paragraph (c) under the existing exemptions to clarify that the term would not include “any fully assembled training round that is not designed (1) for offensive or defensive combat and (2) to be used in a device that constitutes a weapon.” Consequently, importers would not need to complete a Form 6, part I under 27 CFR parts 447 and 478 to bring training rounds into the United States.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) August 4, 2026.
https://www.govinfo.gov/content/pkg/FR-2026-05-06/pdf/2026-08914.pdf
Adding Component Definitions Under the Arms Export Control Act
May 6, 2026: 91 Fed. Reg. 24392: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) proposed amending Department of Justice (“Department”) regulations to include terms that the United States Munitions List uses to describe the composition of defense articles (“compositional terms”). Specifically, the proposed rule would amend Department regulations that implement the Arms Export Control Act (“AECA”) to define the compositional terms “component,” “accessories and attachments,” and “part” for purposes of permanent imports under the AECA.
When ATF examines importing applications that include accessories, attachments, components, or parts, ATF uses either a determination previously made by the Department of State regarding whether a defense article is an accessory, attachment, component, or part; or ATF’s Firearms and Ammunition Technology Division classifies the article relying on the ITAR definitions set forth in 22 CFR 120.40. Because ATF is guided by and largely relies on the Department of State’s views on foreign policy and matters of national security for purposes of the AECA, ATF proposes to add the compositional terms defined in 22 CFR 120.40—“accessories and attachments,” “component,” and “part”—to its AECA regulations so that ATF’s regulations include definitions for these terms and the definitions align with those in the ITAR.
Applying the ITAR’s definition of “part” to the USMIL, however, would require ATF to clarify the defense articles included under Category I—Firearms. 27 CFR 447.21. That category regulates “components and parts” but not “accessories and attachments.” 27 CFR 447.21. Yet the ITAR definition for “part” would include “any single unassembled element of a major or a minor component, accessory, or attachment. . .” 22 CFR 120.40 (emphasis added). Fully applying the ITAR definition of “part” to the USMIL Category I—Firearms would consequently lead to the result that unassembled accessories or attachments (falling under the definition of “part”) would be regulated while complete accessories or attachments would not. Therefore, ATF proposes to use paragraph (e) of Category I—Firearms, which is currently reserved, to add a sentence clarifying that “components and parts” does not include unassembled elements of an accessory or attachment. Category I—Firearms would thus include components of regulated firearms as well as unassembled elements of a component, but it would exclude assembled or unassembled attachments and accessories.
Adding the ITAR’s definitions would better inform importers of defense articles under the AECA and enable ATF to define these terms consistently when approving or denying import applications. The changes would also ensure that ATF and the Department of State align in how they use these compositional terms with respect to the USMIL and USML. And the proposed clarification within the USMIL would retain the current scope of defense articles regulated under USMIL Category I—Firearms.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) July 6, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
Export Control Reform-Conforming References to Department of Commerce
May 6, 2026, 91 Fed. Reg. 24352: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) is amending Department of Justice (“Department”) regulations to make administrative and technical clarifying revisions. These revisions add conforming references to the Department of Commerce in the relevant processes, and respond to regulatory changes already made by the Departments of Commerce and State that have effectively divided export and temporary import controls between those two agencies. The revisions also make minor technical amendments to punctuation for better clarity.
This direct final rule updates ATF’s regulatory provisions by adding references to the Department of Commerce in 27 CFR part 447 (regulations promulgated under the AECA) and 27 CFR part 479 (regulations promulgated under the NFA) to conform to the Department of Commerce’s control over certain items as a result of the ECR. More specifically, this direct final rule adds references to the Department of Commerce in the applicable sections in parts 447 and 479 to refer to those transactions that implicate the Department of Commerce’s export and temporary import jurisdiction.
- 27 CFR Part 447, Importing Arms, Ammunition, and Defense Articles
This direct final rule amends the articles-in-transit provision at 27 CFR 447.46 to add a reference to the Department of Commerce and its EAR at 15 CFR 758.10. Articles subject to 27 CFR part 447 import permit procedures that are entering the United States only temporarily pending removal, and articles temporarily taken out of the United States for subsequent return to the United States, are not considered imported or exported for part 447 purposes. Those temporary import and temporary export transactions are now subject to in transit or temporary export procedures of either the Department of State or the Department of Commerce. In addition, this rule makes a minor plain writing edit to remove the words “shall be” and “will be,” replacing the first with the word “are.”
This direct final rule also amends the exemption provisions at § 447.53(a)(3) and (b) to add references to the Department of Commerce after existing references to the Department of State. Section 447.53(a)(3) currently states that part 447 provisions do not apply to importing articles (other than firearms as defined in 18 U.S.C. 921(a)(3)) manufactured in foreign countries for persons in the United States that are subject to Department of State approval. ATF is adding “or Department of Commerce” after “Department of State” to conform to the regulatory changes made through the ECR such that the exemption applies to articles subject to either department’s approval. The provision at 27 CFR 447.53(b) currently states that any person seeking to import USMIL defense articles exempt under § 447.53(a) may obtain release of such articles from Customs custody by submitting, to the customs officer with authority to release, a statement claiming the exemption accompanied by satisfactory proof of eligibility. The proof may be in the form of a letter from the Department of Defense or State, as the case may be, confirming the person has met the exemption conditions. This direct final rule replaces “Department of Defense or State” with “Departments of Defense, State, or Commerce” in § 447.52(b).
Additionally, this direct final rule makes technical amendments to § 447.53(a)(1)-(3) to change the word “importation” to “importing” where it appears in each paragraph, and to § 447.53(a)(3) to add a missing punctuation mark, specifically to close the parenthetical phrase that ends after the citation “18 U.S.C. 921(a)(3),” and to change the term “Customs” to the term “Customs and Border Protection” and its subsequent abbreviation, to conform with that agency’s preference.
- 27 CFR Part 479, Machine Guns, Destructive Devices, and Certain Other Firearms
This direct final rule also amends the requirements at § 479.122(b), on exporting firearms caliber .22 or larger, by adding a conforming reference to the Department of Commerce—“other authorization from” in addition to the license requirement—due to Department of Commerce practices. In addition, this rule amends the requirements (1) by restructuring the last sentence to clarify up front that the person must obtain the license or authorization prior to exporting, rather than mentioning that at the end as the existing regulation does, and (2) by providing the public updated contact information for the Department of State and for the Department of Commerce regarding export authorizations.
Finally, the direct final rule adds to § 479.122(b) a new last sentence to simply remind exporters of an existing obligation, which is that they should abide by the terms and conditions of the applicable exemption or license exemption prior to exporting firearms caliber .22 or larger. This sentence reads, “Any such person should also comply with the terms and conditions of an applicable Department of State exemption or Department of Commerce license exception prior to exporting such firearms.” As described above, these changes are necessary to bring ATF’s export control regulations into conformity with changes made in March 2020 as a result of the ECR. Those changes included a split of Department of State authority over export and temporary import controls between the Department of State and the Department of Commerce, which now both control export and temporary import controls for items that are USMIL defense articles that are also controlled by ATF for permanent import purposes.
This direct final rule is effective on July 6, 2026, unless significant adverse comments are received by June 5, 2026. If ATF receives a significant adverse comment within the stated time that warrants revising the rule (as described under the “Public Participation” heading in the SUPPLEMENTARY INFORMATION section of this regulation at part IV of this preamble), ATF will publish a notice in the Federal Register withdrawing the rule before the effective date. Commenters should be aware that the https://www.regulations.gov comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
Revising Regulations Defining “Engaged in the Business” as a Dealer in Firearms
May 6, 2026: 91 Fed. Reg. 24424: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) issued a proposed rule to revise regulations implementing the “engaged in the business” definition from the Bipartisan Safer Communities Act (“BSCA”). Although Congress defined that term in BSCA, the Department of Justice (“Department”) provided additional definitions in its implementing regulations to further define terms within the statutory definition and to include examples of covered activities that established rebuttable presumptions of being engaged in the business of dealing in firearms. This rule proposes to remove those changes. ATF has determined that the changes have not shown the expected impact on federal firearms licensee applications, administrative licensing actions, civil forfeitures, or other anticipated effects.
The Department published a final rule, titled “Definition of `Engaged in the Business’ as a Firearms Dealer,” 89 FR 28968 (Apr. 19, 2024) (“EIB rule”), which became effective on May 20, 2024. The EIB rule amended the regulations in 27 CFR part 478 to (1) incorporate BSCA’s definition of the term “engaged in the business,” (2) provide clarification and guidance on what it means to be “engaged in the business” and to have the requisite intent to “predominantly earn a profit,” and (3) identify conduct that was presumed to constitute “dealing” and to show relevant intent. The EIB rule also defined the term “responsible person” and addressed the procedures former licensees must follow when they liquidate business inventory when their license is terminated.
ATF believes that the EIB rule is replete with procedural and substantive problems. Consequently, ATF proposes repealing those sections of the EIB rule that do not correctly implement the GCA and BSCA. ATF does not propose, however, to repeal the EIB rule in its entirety. Some sections of the EIB rule will be retained—for example, those providing for the discontinuance of business operations—although this rule proposes to amend some of those provisions.
ATF proposes the following regulatory changes related to the definition of engaged in the business as a dealer as implemented in §§ 478.11 and 478.13 via the EIB rule. ATF proposes to (1) move the current definition of “engaged in the business as a dealer in firearms other than a gunsmith or pawnbroker,” set forth in §§ 478.13(a) to 478.11, and (2) rescind § 478.13(b)-(h). Paragraphs (b) through (h) of § 478.13 include: (b) a statement that whether a person is engaged in the business as a dealer in firearms other than a gunsmith or a pawnbroker is a fact-specific inquiry, (c) specific fact-patterns establishing presumption that a person is engaged in the business as a dealer, (d) the definition of “predominantly earn a profit,” (e) a list of conduct that does not support a presumption, (f) evidence that may be used to rebut a presumption, (g) clarification that itemized presumptions, conduct, and rebuttal evidence are not exhaustive lists, and (h) clarification that the rebuttable presumptions do not apply to criminal proceedings.
ATF also proposes to retain the definition of “predominantly earn a profit” from § 478.13, with some revisions, and move it to § 478.11. The rest of § 478.13 would be removed, except as provided in the following paragraph. ATF is also proposing to change the definition of “personal collection” and remove the definition of “former licensee inventory,” both in § 478.11. These proposed changes are described in detail below.
ATF proposes removing all of § 478.13 except: (1) the portion of the definition of “engaged in the business as dealer in firearms other than gunsmith or pawnbroker” that duplicates statutory language in 18 U.S.C. 921(a)(21)(C); (2) the added exception for auctioneers who provide only auction services on a commission by assisting persons to liquidate firearms in an estate-type sale; and (3) a revised version of the definition of “predominantly earn a profit.” Because these remaining portions of § 478.13 would no longer be long enough to warrant a separate definition section, ATF proposes moving all three of these remaining portions from § 478.13 to § 478.11 (meaning of terms), where other relatively short definitions are located.
ATF would place the definition of engaged in the business as a dealer under paragraph (3) in the definition of “engaged in the business,” and the existing language in paragraph (3), which references § 478.13, would be removed. The paragraph would retain the same heading and would read, “A person who devotes time, attention, and labor to dealing in firearms as a regular course of trade or business to predominantly earn a profit through the repetitive purchase and resale of firearms. The term does not include a person who makes occasional sales, exchanges, or purchases of firearms to enhance a personal collection or for a hobby, or who sells all or part of the person’s personal collection of firearms.”
ATF would also move the auctioneer exception to paragraph (3) within the definition of “engaged in the business” under § 478.11, at the end of the new paragraph described above. Historically, licensees and non-licensees seeking guidance on the proper and lawful way to liquidate firearms, both in the regular course of their business or as an isolated occurrence, have commonly raised questions about auctioneers. Because ATF has regularly provided consistent guidance on what type of auction activity crosses the threshold to constitute engaging in the business of dealing in firearms, the portion of the definition that incorporates that exception into the regulation provides definitional clarity to the public and licensed community. Therefore, ATF proposes retaining the portion of § 478.13 that codifies ATF’s historical position, thus ensuring consistency for industry members. Modifying or removing this part of the definition would likely cause undue and unnecessary confusion. This proposed change would therefore add the following text to the end of paragraph (3): “In addition, the term does not include an auctioneer who provides only auction services on commission to assist in liquidating firearms at an estate-type auction, as long as the auctioneer does not purchase the firearms or take possession of the firearms for sale or consignment.”
ATF would move the text of the definition in § 478.13 of “predominantly earn a profit” to a location under the same definitional heading in § 478.11, and it would remove the text currently under that heading, which references § 478.13. It is necessary to retain this definition to distinguish between, on the one hand, what constitutes engaging in the business as a dealer in firearms other than a gunsmith or pawnbroker; and, on the other hand, engaging in the business as a gunsmith, pawnbroker, manufacturer, or importer—all of which continue to require the “principal objective of livelihood and profit” that applied to dealers prior to BSCA. The definition of “predominantly earn a profit” tracks the statutory definition; however, ATF proposes making a minor change to one sentence of the definition, so it is easier to read, without changing the meaning. Specifically, ATF proposes changing the sentence, “ Provided, that proof of profit, including the intent to profit, shall not be required as to a person who engages in the regular and repetitive purchase and disposition of firearms for criminal purposes or terrorism,” to “However, proof of profit, including the intent to profit, is not required in cases in which the person engaged in regular and repetitive purchase and disposition of firearms for criminal purposes or terrorism.” This change is in line with one of the purposes for ATF’s implementing regulations, which is to aid the public in understanding and complying with statutory provisions, and it is consistent with laws requiring plain writing. It does not modify or expand on the statutory meaning.
In addition, ATF proposes to remove the last sentence of the definition as it currently exists in § 478.13, which reads, “For purposes of this section, a person may have the intent to profit even if the person does not actually obtain the intended pecuniary gain from the sale or disposition of firearms,” because this sentence is not in the statutory definition. The proposed new definition of “predominantly earn a profit” would thus be “The intent underlying the sale or disposition of firearms is predominantly one of obtaining pecuniary gain, as opposed to other intents, such as improving or liquidating a personal firearms collection. However, proof of profit, including the intent to profit, is not required in cases in which the person engaged in the regular and repetitive purchase and disposition of firearms for criminal purposes or terrorism.”
In addition to the above changes to § 478.13, ATF proposes two changes directly to § 478.11. Specifically, for the reasons discussed in section II.A of this preamble, ATF proposes removing paragraph (1) of the definition of “personal collection (or personal collection of firearms, or personal firearms collection),” moving paragraph (2) up to replace paragraph (1) with changes necessary to conform it to regulatory paragraph designations, changing the definition’s title to reflect the remaining content, and removing the definition “former licensee inventory” entirely. The proposed heading for the definition of “personal collection (or personal collection of firearms, or personal firearms collection)” would instead be “licensee personal collection (or personal collection of licensee).” The rest of the definitional text would remain the same as currently in § 478.13, but the paragraph designation would change because it would no longer be paragraph (2).
In addition, the rule proposes to make changes to § 478.57 (Discontinuance of business). The proposed rule would remove from paragraphs § 478.57(b)(2) and (c) the relevant sentences that effectively restrict former licensees from reselling their firearms without being presumed to be engaged in the business. Specifically, it would remove from § 478.57(b)(2) the sentence that reads: “Any such transfer, however, does not negate the fact that the firearms were repetitively purchased, and were purchased with the predominant intent to earn a profit by repetitive purchase and resale.” And it would remove from § 478.57(c) the second sentence that provides that a former FFL who resells any of its former business inventory is subject to the provisions of § 478.13. Because this rule proposes to remove § 478.13, the provisions in these paragraphs would no longer be relevant. And because these provisions are also found in § 478.78 (Operations by licensee after notice), this rule proposes to remove from § 478.78(b)(2) and (c) the same sentences.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) August 4, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
Converting Temporary to Permanent Imports for Defense Articles
May 8, 2026: 91 Fed. Reg. 25159: The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) issued a proposed rule to amend Department of Justice (“Department”) regulations regarding the permanent import provisions of the Arms Export Control Act (“AECA”). The proposed rule would allow importers to apply for ATF authorization to convert items imported temporarily—under a Department of State (“DOS”) authorization or under the entry clearance requirements for temporary imports in the Export Administration Regulations (“EAR”) maintained by the Department of Commerce (“DOC”)—to permanent imports in compliance with other applicable federal firearms laws, without having to export and then reimport the items.
ATF proposes amending the definition of “Import or importation” in 27 CFR 447.11 to indicate that importing ( i.e., permanently importing) occurs not only when an article is brought into the United States as a permanent import, but also when an article, lawfully in the United States pursuant to a DOS authorization or pursuant to meeting DOC’s entry clearance requirements for temporary imports under 15 CFR 758.10, is converted to remain in the United States permanently before the DOS authorization expires or while still in compliance with 15 CFR 758.10 entry clearance requirements. This proposed change to the definition would permit ATF to process a Form 6, part I, for items currently in the United States as temporary imports and, if otherwise authorized by law, permit the importer to convert these articles to permanent imports. This would establish a clear process by which importers could avoid unnecessary costs while ensuring that such imports remain subject to ATF review and are in compliance with federal law. Temporary imports of ITAR defense articles subject to DOS authorization or defense articles subject to DOC EAR clearance requirements would also remain subject to ITAR or EAR jurisdiction until DOS or DOC, respectively, recognizes a change in end user or end use.
ATF also proposes amending 27 CFR 447.42 by adding a new paragraph (c), which would provide a process through which an importer can apply to convert a temporarily imported item to a permanently imported one by submitting a Form 6, part I, to ATF for approval. Specifically, this rule would require importers to indicate on Form 6, part I, that they intend to convert the temporarily imported item to a permanently imported one and to submit with it a copy of the DSP-61 issued by DOS, entry documents showing that they claimed an ITAR exemption, or a copy of the temporary import entry clearance documents provided to CBP pursuant to DOC’s entry clearance requirements. This would eliminate a potentially wasteful regulatory barrier without negatively impacting public safety or otherwise permitting importers to circumvent statutory importing restrictions.
Because neither the GCA nor the NFA exempts temporarily imported items pursuant to DOS authorization or DOC clearance requirements from their definition, such temporary imports must comply with GCA and NFA restrictions and their implementing regulations at parts 478 and 479, just as permanent imports must. As a result, this rule does not propose any changes to those regulatory provisions. By proposing to add the requirement to submit a Form 6, part I, application for ATF approval when converting, this rule would ensure compliance with the AECA as well. Under the existing regulation at 27 CFR 447.44, ATF has the authority to deny applications for AECA import permits—which would include the conversion applications proposed in this rule—when importing as requested would be “inconsistent with the purpose or in violation of” the AECA or its implementing regulations in 27 CFR part 447. Additionally, ATF would deny applications if the conversion does not comply with the import provisions of the GCA and NFA.
Moreover, ATF proposes to amend 27 CFR 478.112 by adding a new paragraph (e) to clarify the marking requirements for firearms converted to permanently imported items under this process. Currently, § 478.112 requires that importers comply with marking requirements within 15 days after CBP releases the firearms from its custody. However, this time period does not work in the case of temporary-to-permanent conversions because the items are not in CBP custody once they have been imported as temporary items and released. So, in the case of temporary imports, items may have been exempt from the GCA or NFA marking requirements and might not be marked at the time the items are released from CBP custody—and thus might not be marked at the time the importer wants to convert them to permanent imports. The amendment to § 478.112(e) would provide that, in such cases, the importer must ensure converted items are marked as required by the GCA and NFA within 15 days after ATF approves a Form 6, part I, to convert them from temporarily imported items to permanently imported ones. In addition, the new paragraph would include a requirement that the importer also submit a Form 6A to ATF within that same timeframe, to reflect that these items are being converted to permanent imports, and to record their serial numbers, as required for items imported on a permanent basis in the first instance.
ATF is also proposing minor plain writing and other technical amendments to §§ 447.11, 447.42 (particularly in paragraphs (a) and (b), which have no substantive changes), 478.11, and 478.112 (particularly in paragraphs (a)-(d), which have no substantive changes) to make the definitions and instructions easier to read, including using the term “importing” instead of “importation,” reducing passive voice, substituting “U.S. Customs and Border Protection” and “CBP” thereafter for “Customs,” and updating headings and form numbers and names.
ATF also notes that other non-conflicting changes to §§ 478.11 and 479.11 are being proposed in a separate notice of proposed rulemaking to amend the definition of “importation” as it pertains to foreign trade zones and custom bonded warehouses.
Comments must be submitted in writing, and must be submitted on or before (or, if mailed, must be postmarked on or before) August 6, 2026. Commenters should be aware that the federal e-rulemaking portal comment system will not accept comments after midnight Eastern Time on the last day of the comment period.
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
Four Defendants Convicted in Plot to Kill Haitian President Jovenel Moïse
A federal jury in Miami today convicted four defendants for their roles in the July 7, 2021, assassination of Haitian President Jovenel Moïse.
Arcangel Pretel Ortiz, Antonio Intriago, Walter Veintemilla, and James Solages were convicted of conspiracy to provide material support or resources to carry out a violation of 18 U.S.C. § 956, resulting in death; providing material support and resources to carry out a violation of 18 U.S.C. § 956, resulting in death; conspiracy to kill and kidnap a person outside the United States; conspiracy to commit offenses against the United States; and expedition against a friendly nation. Intriago was also convicted of a third count of conspiracy to commit offenses against the U.S.; smuggling goods from the U.S.; and submitting false or misleading export information.
“This case exposed a far-reaching criminal conspiracy driven by power, profit, and political ambition that extended well beyond Haiti’s borders,” said Acting Special Agent in Charge Jose R. Figueroa of Homeland Security Investigations (HSI) Miami. “HSI and our partners followed the evidence across jurisdictions and international boundaries to help hold accountable those responsible for this heinous plot to assassinate a sitting president and destabilize a partner nation.”
Veintemilla played a central role in financing the conspiracy. Starting in April 2021, Veintemilla agreed to finance the scheme through a $175,000 loan agreement financed with proceeds derived from others’ Coronavirus Aid, Relief, and Economic Security (CARES) Act’s Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL) funds that were funneled through an account controlled by a co-conspirator. Trial evidence also showed that Veintemilla was involved in the operational details. After learning of the assassination in the early morning hours of July 7, 2021, Veintemilla immediately called a co-conspirator and proclaimed: “the rat (President Moïse) is in the box.”
Pretel Ortiz, who referred to himself as “Colonel Gabriel” and routinely wore fake U.S. military-style uniforms, rank, and insignia, directed the plot’s tactical planning and operation, including coordinating with the Colombian mercenaries. Hours before the assassination, Pretel Ortiz told his co-defendants: “I put my men on the ground and we are still fighting to reach the objective.”
Intriago, Pretel Ortiz’s business partner, handled the day-to-day logistical aspects of the plot, including payroll, equipment, and provisions for the co-conspirators. On June 10, 2021, Intriago helped smuggle bulletproof vests and other tactical equipment—including radios, flashlights, and goggles—from Miami to Haiti for use by the Colombian mercenaries during the assassination. In late June 2021, Intriago traveled to Haiti and photographed himself with the group’s Haitian allies. On the eve of the assassination, Intriago messaged his co-conspirators: “We finally got the tools to do the work.”
Solages served as the defendants’ primary liaison in Haiti and repeatedly traveled between South Florida and Haiti to coordinate with Haitian gang leaders, obtain weapons and ammunition in Haiti, and conduct surveillance of President Moïse’s residence. Solages also accompanied the Colombian mercenaries during the attack and instructed them to kill everyone inside the house, including “the dog, the cat, and parrot.”
All four defendants face maximum penalties of life in prison. U.S. District Judge Jacqueline Becerra for the Southern District of Florida will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.
FBI Miami and HSI Miami investigated the case, with valuable assistance from the Department of State; the Bureau of Alcohol, Tobacco, Firearms and Explosives; the U.S. Department of Commerce, Bureau of Industry and Security, Office of Export Enforcement; and the Department of Defense Criminal Investigative Service.
https://www.justice.gov/opa/pr/four-defendants-convicted-plot-kill-haitian-president-jovenel-moise
Arcadia, California, Mayor Federally Charged with Acting as Illegal Agent of the People’s Republic of China
May 11, 2026: The Department of Justice announced the mayor of Arcadia, California, has been charged in federal court with acting as an illegal agent of the People’s Republic of China (PRC), the Justice Department announced today.
Wang was elected in November 2022 to the Arcadia City Council, a five-person governing body from which the mayor is selected on a rotating basis.
“By her own admission, Eileen Wang secretly served the interests of the Chinese government,” said Assistant Director Roman Rozhavsky of the FBI’s Counterintelligence and Espionage Division. “Let this serve as a clear warning: individuals who act on behalf of foreign governments to influence our democracy will be identified, investigated, and brought to justice. Protecting the rule of law and the transparency of our democratic process remains at the core of the FBI’s mission, and we will continue working alongside our partners to safeguard the integrity of our elections and keep hostile actors from undermining the voices of the American people.”
According to her plea agreement, from late 2020 through 2022, Wang and Yaoning “Mike” Sun, 65, of Chino Hills, California, worked at the direction and control of PRC government officials and coordinated with U.S.-based individuals to promote the PRC’s interests by, among other things, promoting pro-PRC propaganda in the United States. Sun is serving a four-year federal prison sentence after he pleaded guilty in October 2025 to acting as an illegal agent of a foreign government.
Wang and Sun worked together to operate U.S. News Center, a website that purported to be a news source for the local Chinese American community. Wang and Sun received and executed directives from PRC government officials to post pro-PRC content on the website.
In a related filing, Wang has agreed to plead guilty to the felony count, which comes with a maximum penalty of 10 years in prison
Luxury Yacht Companies Plead Guilty to Violating Lacey Act for Using Illegally Obtained Burmese Teak on Multimillion Dollar Yachts; Agree to Pay $200,000 Fine
May 13, 2026: The Department of Justice announced Sunseeker International Limited and Sunseeker USA Sales Co. Inc. (Sunseeker) pleaded guilty to two violations of the Lacey Act for using illegally obtained Burmese Teak on yachts that it imported into the United States. Sunseeker agreed to pay a fine of $200,000, and to implement a compliance plan, among other penalties. Sunseeker manufactures luxury performance motor yachts and superyachts.
Sunseeker manufactures its vessels in the United Kingdom (U.K.) and sells them internationally, including in the United States. Sunseeker pleaded guilty to using Burmese Teak on their yachts, specifically, a Teak balcony door intended to be incorporated into a yacht, and Teak parts incorporated into two yachts priced at approximately $2.98 million and $1.07 million, respectively.
The illegal logging of Teak in Myanmar has been a known problem since at least 2017. Both the U.S. and the U.K. have imposed sanctions against Myanmar and the U.S. has sanctioned the Myanma Timber Enterprise (MTE), the sole authorized seller of export Teak harvested in Myanmar. U.S. sanctions prohibit all transactions by U.S. persons or those transiting the U.S. that involve any property or interest in property associated with the MTE. The U.K. has concluded that timber harvesting, specifically Teak, has financially supported dictatorships in Myanmar.
Sunseeker was previously charged in the U.K. and pleaded guilty in 2023 to three criminal violations of the U.K.’s Timber and Timber Products Regulations (UKTR). The company was sentenced and fined approximately $450,000. The Teak imports that Sunseeker imported into the U.S. came from the illegal Teak imports charged in the U.K. case.
Homeland Security Task Force Arrests Maduro Regime Ally Alex Saab on Money Laundering Charges Involving Venezuelan Food Contracts and Oil
May 18, 2026: The Department of Justic announced the indictment of Alex Nain Saab Moran, 55, a Colombian national and Venezuela’s former Ministry of Industry and National Production, who allegedly conspired with others to bribe Venezuelan public officials to secure lucrative Comité Local de Abastecimiento y Producción (CLAP) contracts to import food into Venezuela. Saab is accused of conspiring with others to fraudulently misrepresent the nature and source of the food supplies, including falsely documenting imports from Colombia and Mexico.
“This indictment alleges that a humanitarian food program intended to support vulnerable Venezuelans was instead manipulated for massive personal enrichment,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “According to the charges, the defendant used bribery, shell companies, and fraudulent documents to siphon hundreds of millions of dollars for personal gain. When illicit proceeds are moved through the United States financial system, our courts have jurisdiction and our prosecutors will act. The charges are allegations, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt.”
Rather than fulfilling the contracts, Saab and his co-conspirators secretly used shell companies, fraudulent invoices, falsified shipping records, and other fabricated documents — along with a network of bribes and kickbacks — to siphon off hundreds of millions of dollars that were intended to be used to purchase food for needy Venezuelans. Portions of the illicit proceeds were allegedly spent or concealed through transfers to and through bank accounts in the U.S.
The indictment further alleges that, from 2019 through at least January 2026, the conspiracy expanded as U.S. economic sanctions crippled Venezuelan exports, especially oil, placing severe strain on the country’s finances and its ability to meet its foreign debt obligations, including payments to Saab and his co-conspirators as part of the CLAP program. Exploiting their corrupt relationships with government officials, Saab and his co-conspirators allegedly gained access to billions of dollars’ worth of oil owned by Venezuelan state-owned Petróleos de Venezuela, S.A. (PDVSA) and sold it under false pretenses.
Proceeds from those illegal sales were then transferred to and through U.S. bank accounts to further promote and conceal the CLAP scheme.
Saab is charged with conspiracy to launder monetary instruments. If convicted, he faces a maximum penalty of 20 years in federal prison.
Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Adani Enterprises Limited
May 18, 2026: The Office of Foreign Assets Control (OFAC) announced a $275,000,000 settlement with Adani Enterprises Limited (AEL), an Ahmedabad, India-based company. AEL agreed to settle its potential civil liability for 32 apparent violations of OFAC’s Iran sanctions. From November 2023 to June 2025, AEL purchased shipments of liquified petroleum gas (LPG) from a Dubai-based trader purporting to supply Omani and Iraqi gas.
AEL acted recklessly by ignoring red flags point to potential links to Iran. These included warnings received from third parties that LPG cargos being imported by AEL may have been of Iranian-origin, and the economic, commercial, and logistical implausibility of the cargos’ origin and pricing. AEL also did not conduct additional due diligence that may have revealed that the vessels carrying its LPG cargos routinely engaged in suspicious behavior such as Automatic Identification System manipulation, uneconomic or illogical vessel movements or port calls, and frequent name, ownership, and flag state changes.
During this time period, AEL caused U.S. financial institutions to process 32 U.S. dollar denominated payments totaling approximately $192,104,044 for the shipments. The settlement amount reflects OFAC’s determination that AEL’s apparent violations were egregious and not voluntarily self-disclosed and further reflects the AEL’s remedial measures following discovery of the conduct and the cooperation AEL provided for OFAC’s investigation
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=fbc320619774cb14fe5c39b0f053af77
https://ofac.treasury.gov/media/935636/download?inline https://ofac.treasury.gov/media/935631/download?inline
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Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for May 1 through May 31, 2026.
- Iran-related Designations; Issuance of Iran-related General License and Frequently Asked Question; Publication of Iran-related OFAC Alert
https://ofac.treasury.gov/recent-actions/20260501
- Issuance of Executive Order Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security And Foreign Policy
https://ofac.treasury.gov/recent-actions/20260501_33
- Issuance of Venezuela-related General License and Amended Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260504
- Issuance of Venezuela-related General License
https://ofac.treasury.gov/recent-actions/20260505
- Counter Terrorism and Iran-related Designations; Cuba Designation and Designations Updates; Issuance of Cuba-related General License and Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260507
- Counter Terrorism and Counter Narcotics Designation Update, Russia-related Designation Removal
https://ofac.treasury.gov/recent-actions/20260508
- Non-Proliferation and Iran-related Designations and Designations Updates
https://ofac.treasury.gov/recent-actions/20260508_33
- Counter Terrorism Designations; Iran-related Designations
https://ofac.treasury.gov/recent-actions/20260511
- Notice with Regard to International Criminal Court-related Sanction
https://ofac.treasury.gov/recent-actions/20260515
- Cuba Designations and Designations Updates; Issuance of Russia-related General License
https://ofac.treasury.gov/recent-actions/20260518_33
- Counter Terrorism Designations; Iran-related Designations
https://ofac.treasury.gov/recent-actions/20260519
- Counter Narcotics and Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260520
- International Criminal Court-related Designation Removal
https://ofac.treasury.gov/recent-actions/20260520_33
- Counter Terrorism Designations
https://ofac.treasury.gov/recent-actions/20260521
- International Criminal Court-related Designation
https://ofac.treasury.gov/recent-actions/20260527 - Iran-related Designation; Counter Terrorism Designation
https://ofac.treasury.gov/recent-actions/20260527_33 - Iran-related Designations; Issuance of Russia-related General License and Amended Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260528_33
Counter Terrorism Designations; Issuance of Amended Iran-related Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260529