This newsletter is a listing of the latest changes in export control regulations through November 30, 2025. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
REGULATORY UPDATES
Department of State, Directorate of Defense Trade Controls (DDTC)
DDTC Name And Address Changes Posted To Website
November 5, 2025 through November 12, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Address Change of K Line Logistics Ltd. From Nagoya Branch, 17-7, Sannou 3-chome, Nakagawa-ku, Nagoya, Aichi 445-0011, Japan To Marunouchi One Building 5F, 1-9-16 Marunouchi, Naka-Ku, Nagoya, Aichi 460-0002, Japan;
- Change in Name From Goodrich Lighting Systems GmbH & Co. KG To Goodrich Lighting Systems GmbH due to corporate rebranding; and
- Change in Name From SKY Perfect Holdings Inc. To SKY Perfect JSAT Corporation due to merger.
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DDTC Final Commodity Jurisdiction Determinations Posted To Website
November 19, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between May 5, 2025 and October 31, 2025, on its website at:
| Model Name | Manufacturer | Description | Final
Determination |
Final Determination Date |
| Printed Circuit Board for Part Number 645D0100-1 | EMS Development Corporation | A printed circuit board (PCB) assembly used primarily to interface with a display providing system operation information and control of a Solid-State Voltage Frequency Converter (SSVFC) | USML Category XI(a)(7) | 5/15/2025 |
| .308 caliber 147gr Full Metal Jacket Projectile, Part Number .308-FMJ-BULLET | Vaughan Enterprises, LLC | Full Metal Jacket Projectile with a 220 copper alloy jacket | CCL ECCN 0A505.x | 5/15/2025 |
| Assistance Building Ice Protection System on the European Medium Altitude Long Endurance Remotely Piloted Aircraft System (MALE RPAS) | Cox & Company, Inc. | A service that includes the design and installation of an ice protection system on the wings and tail of the MALE RPAS | Assistance constitutes a defense service as defined in ITAR § 120.32(a)(1) and described on USML Category VIII(i) | 5/15/2025 |
| Ten Flight Parameters for the C-17 Aircraft | The Boeing Company | Ten Flight Parameters for the C-17 Aircraft | USML Category VIII(i), except when in the public domain | 5/15/2025 |
| Cape Service, Cape App, Cape Mobile Core and Cape Phone (Cape Platform) | Private Tech Inc. dba: Cape |
Components of a platform from an early-stage startup mobile virtual network operator (MVNO) that seeks to serve as a more private and secure mobile carrier for privacy-conscious consumers. | CCL ECCN 5A002.a | 5/15/2025 |
| Workload Security Proxy (WoSP), Models XTRA-01 and K4C-01 | Hopr Corporation | Workload Security Proxy (WoSP), Models XTRA-01 and K4C-01 | Seek a CCATS | 5/19/2025 |
| StormCaster-Dx | Teledyne FLIR, LLC | Multi-role EO/IR turret with a laser target designator designed for use on a military UAS | USML Category XII(c)(3) | 5/19/2025 |
| RF Shielded Enclosure - Single Wide – Deep, Model Number: SRC - Deep Cabinet, Part Number: SWD-263884, and RF Shielded Enclosure - Single Wide Standard Height, Model Number: SRC - Single Cabinet, Part Number: SWSH-263084 | Scientific Applications & Research Associates, Inc. (SARA) | Two types of metal enclosures designed for protecting electronics equipment from direct or collateral effects of high-altitude electromagnetic pulses (HEMP) and other electromagnetic (EM) events | USML Category XVIII(b) | 5/19/2025 |
| Mira 02Y-E VIS/SWIR Camera, Part Number 43-00180-01 (and variants) | Quantum Imaging, Inc. | A low size, weight, and power (SWaP) visible/short-wave infrared (VIS-SWIR) camera with a spectral response from 0.4 to 1.7 micrometers | CCL ECCN 6A003.b.4.a | 5/19/2025 |
| LiSA - LIDAR for Situational Awareness, Part Number 110630-0001 | Arete Associates | LIDAR that provides real-time situational awareness for helicopter operations | USML Category XII(b)(6) | 5/19/2025 |
| Analog-to-Digital Converter, Part Number ADS-30353 | Data Device Corporation | Integrated microcircuit | USML Category XI(c)(3) | 5/28/2025 |
| SIR-2002 | FEI-ELCOM TECH, INC. | A very high frequency (VHF) and ultra-high frequency (UHF) digital signal processing (DSP) monitoring receiver | USML Category XI(c)(14) | 5/28/2025 |
| 2nd Generation Radar Scene Emulator (2GRSE) | Keysight Technologies, Inc. | Automotive radar test system | USML Category XI(c)(8) | 5/28/2025 |
| Arm Assembly, Torque, LC130 Ski, Part Number 201612214-10 | Air New Zealand | Mechanism for lifting and lowering the LC130 nose ski for flight and landing on ice | CCL ECCN 9A610.x | 5/28/2025 |
| 2124-T8151 Aluminum Pylon Blank, M/N 1756, P/N LMA-M7008 | Reliance Steel & Aluminum Co. | Aluminum blank shaped to the approximate geometry of a pylon component | USML Category VIII(h)(6) | 5/28/2025 |
| Archimedes Laser Sentinel, Model Prototype | Aurelius Systems Inc | laser system designed to track and target drones | USML Category XVIII(a) | 5/28/2025 |
| Fixed Wing Expeditionary Landing Zone Kit, part number: AZL-PK9001-AZL9 | Phantom Products, Inc. | Lighting for expeditionary aircraft landing zones | USML Category XII(c)(8) | 5/28/2025 |
| 24mm diameter Polymer Nanoguide Faceplate, Part Number: 180-7975 | Incom, Inc | Faceplate for projector assemblies in advanced aviator helmets | USML Category VIII(h)(15) | 6/1/2025 |
| Rotor and drive system associated with AVX’s CCH Aircraft, and related technology | AVX Aircraft Company | A scalable coaxial helicopter rotor system and related technology | Seek a CCATS | 6/1/2025 |
| Cycle Automated Mass Flow (CAMFlow), versions 1 through 4 | CU Aerospace, LLC | Flow controller for CubeSat propulsion systems | ECCN 9A515.x | 6/9/2025 |
| Molten Chloride Fast Reactor (MCFR), Balance-of-Plant Systems and Equipment, and Associated Technology | TerraPower, LLC | Nuclear reactor designed for civil maritime nuclear propulsion, supporting components and auxiliary systems the MCFR needs to produce useful energy, and associated reactor technology | Molten Chloride Fast Reactor (MCFR): Subject to the Jurisdiction of the Nuclear Regulatory Commission, administered by the Department of Energy (DOE)The Balance-of-Plant and the Associated Technology: Seek a CCATS for portions not regulated by NRC DOE |
6/9/2025 |
| STAR-GOAT (Sequential Tester for Aerospace Research - Ground & Operation Acceptance Testing), Model Number: STAR-GOAT v 2.11 | James Kring Inc. (JKI) | Software used to control the testing of rocket engine propulsion systems | Seek a CCATS | 6/9/2025 |
| Mantis Model i45 N, Part Number 88135 (“i45N”) | Aerovironment, Inc. | Multi-sensor low-light gimballed camera | USML Category XII(c)(3) | 6/9/2025 |
| Switch, SP2T, Model DS0860/B1 Rev A | Daico Industries, Inc. | Radiofrequency switch | USML Category XII(e)(1) | 6/16/2025 |
| Babcock BITE, Part Number: BITE-002 | Babcock Land Defence Limited | Baseline training simulator, excluding both hardware and software specific to a scenario, weapon, or crew station | Seek a CCATS | 6/20/2025 |
| TeraQ, Part Number TeraQ-001 | Individual | Software-based communication system designed to provide ultra-secure, high-speed data transmission | Seek a CCATS | 6/24/2025 |
| X4-LRF-3K Laser Range Finder, Model X4-LRF-3K (and variants), Part Number MZT002-03-XXX | Maztech Industries, LLC | A laser range finder (LRF) with an integrated visible pointer (for alignment), on-board ballistics computer, and a built-in weather station |
USML Category XII(c)(2)(iii) | 6/24/2025 |
| STAR-200D Air Compressor, NSN 431-01-547-9404 | RIX Industries | Supplies oil-less low-pressure air | CCL ECCN 8A609.x | 6/24/2025 |
| COVERT Software, Version SF-1 | Martian Sky Industries, LLC | Software that produces freedom pose estimations and 3D reconstruction of other spacecraft during close proximity operations | USML Category XV(f) | 7/8/2025 |
| Flash Bainite Steel | Flash SteelWorks, Inc. | Steel plate treated using flash bainite process | Seek a CCATS | 7/8/2025 |
| 40mm HEAT projectile and launcher | Comanche Aerospace Industries, LLC | 40 mm High-Explosive Anti-Tank (HEAT) projectile and launcher for the projectile | USML Category IV(a)(5) 40mm HEAT projectile
USML Category IV(b)(2) 40mm HEAT launcher |
7/8/2025 |
| Detector Assembly E2930-R6233-F-3000300, Rev X and Detector Assembly (2X4X6) E2940-R6231-F-2004000600, Rev X | Hunting Titan, Inc. | Two detector assemblies, each comprised of a scintillation crystal optically coupled to a photomultiplier tube for detection of ionizing radiation | Seek a CCATS | 7/8/2025 |
| Fiber Optic Rotary Joint, part number MR24-155-28-SC | Princetel, Inc | Rotating joint designed to provide continuous transmission of optical signals between a stationary structure and a rotating structure | EAR99 | 7/8/2025 |
| Foreign Military Sales and Security Cooperation Training and Education | Country Intelligence Group LTD dba: CountryIntel | Training designed to help foreign personnel effectively execute and manage U.S. Foreign Military Sales and Security Cooperation programs for their respective countries | Seek a CCATS | 7/8/2025 |
| SKY-100S Phased Array Antenna | Skeyeon | Phased array antenna for a very low earth orbit satellite | USML Category XV(e)(1)(ii) | 7/8/2025 |
| Blast Exposure Monitoring (BEMO) System, Part Number 4989000 | Med-Eng, LLC | Device that measures blast overpressure and noise exposure by recording pressures, accelerations, and acoustics | Seek a CCATS | 8/5/2025 |
| Electrooptical slip ring, Part Number SP54AP02PXM1 | United Equipment Accessories, Inc. | A device that allows equipment to rotate freely, while smoothly electro-optical signals through the device | USML Category XII(e)(8) | 8/5/2025 |
| OverDrive Software and Overland Autonomy Kit | Overland AI | Kit designed to convert a drive-by-wire vehicle into a fully autonomous platform and operating software for the kit | USML Category XI(a)(7) (Kit)
USML Category XI(d) (Software) |
8/5/2025 |
| Composite Overwrapped Pressure Vessel, Linerless, Type V, 2.2 Liter, Model Number: SLT01, Part Number: 118001 | Composite Technology Development, Inc. | A pressure vessel that can store liquids and gases at high pressure | EAR99 | 8/11/2025 |
| Sintered stainless steel wicking material, Part numbers 1978A00 and 1977A00 | Enpro Inc. | Cylinders of sintered stainless steel to be used as wicking material in a power conversion system | Seek a CCATS | 8/11/2025 |
| Multi-Function Muzzle Device (MFMD) 5.56-1.3 | Sparrow Engineering, Inc. | Suppressor developed for use with the select-fire M4 Carbine rifle | USML Category I(e) | 8/11/2025 |
| No 1 (PORT) Air Intake Assembly, part number ACA2237; No 2 Inlet Main Unit Outline, part number ACA2240; and No 3 Inlet Main Unit Outline, part number ACA2243 | Meggitt Aerospace, Ltd | Components of an engine air intake | CCL ECCN 9A610.x | 8/11/2025 |
| M795 155mm Projectile Cell - Robotic Manufacturing Equipment, and directly related services | Weldon Machine Tool, Inc. | Robotic assembly line for 155mm projectiles and directly related services | Split: • M795 Robotic Manufacturing Equipment – Seek a CCATS • Services – USML Category III(e) |
8/11/2025 |
| Force Multiplier Kit modified for an Armored Personnel Carrier; Force Multiplier Kit without customization for any particular vehicle |
Hermes Robotics Inc. | Attachments for motorized ground vehicles that enable remote or automatic operation, making them driver optional | USML Category VII(g)(11): FMK-113-00000
Seek a CCATS: FMK-00000 |
9/5/2025 |
| HUMVEE 9-Man Squad Kit, part number 6121536 | AM General LLC | A kit that converts unarmored HMMWVs into nine-person troop transport and deployment vehicles | USML Category VII(g)(1) | 9/5/2025 |
| OmniLip Seal, Model Number: Series 50; Part Number 501290614 | Saint-Gobain Corporation | A seal designed for a slip ring assembly | Seek a CCATS | 9/5/2025 |
| SDR Series Steel Doors, Models SDR1500 Single; SDDR1500 Double; SDR6000 Single; and SDDR 6000 Double | ASSA ABLOY Specialty Doors, LLC | Forced entry and threat-resistant steel doors and frame assemblies | Split: • USML Category XIII(e)(1) when the door has an Em greater than 1.4 and meets NIJ Level III or better • Seek CCATS when the door either does not have an Em greater than 1.4 or does not meet NIJ Level III |
9/9/2025 |
| Kite-B Unmanned Aircraft System (UAS) | Kite Aerospace Pty Ltd. | Hybrid Vertical Take-off and Landing (VTOL) Fixed-Wing UAS | ECCN 9A012.a.2 | 9/11/2025 |
| Squid Controllers, Part Numbers Squid-Bobcat-T76-T66 and Squid-Caterpillar-963 | Pronto.ai, Inc. | Electronic circuit boards that provide tele-remote control of Bobcat T76 and T66 skid steers and Caterpillar 963 bulldozers | Seek a CCATS | 9/11/2025 |
| Technical Report on a Launch Vehicle using Nuclear Thermal Propulsion, titled "A path to Nuclear Thermal Spaceplanes" | CUBECAB CO. | Technical report for the DOE Phase I STTR grant award DE-SC0025111, describing the technical and regulatory feasibility of launch vehicles using solely nuclear thermal propulsion | Subject to the Jurisdiction of the Department of Energy (DOE) | 9/11/2025 |
| Vadum SkyPro Software and Services Associated with Vadum SkyPro Software | Vadum Inc. | Object labeling, object model management, and analytical solutions software; and directly related services | Software – USML Category XI(b)
Services – USML Category XI(d) |
9/14/2025 |
| D1 Laser Detector, Model D1 | Torrey Pines Logic, Inc. | Wearable laser detector including audible, visual, and tactile signals | Seek a CCATS | 9/18/2025 |
| Customized metal fittings | KME America Marine Tube & Fitting, LLC | Customized metal fittings, including tees, reducers, and elbows | Fitting used in submarines – USML Category XX(c) Fitting used in surface vessels – CCL ECCN 8A609.y.2 |
9/23/2025 |
| Five Satellite Simulators (SATSIMs): Single Channel Satellite Simulator, Model Number: 1-Channel, Part Number: USS-101-001; Single Channel Briefcase Satellite Simulator, Model Number: 1-Channel Briefcase Satellite Simulator, Part Number: USS-101-002A; Dual Channel Satellite Simulator, Model Number: Dual Channel, Part Number: USS-101-003; 2-Channel Briefcase Satellite Simulator, Model: 2-Channel Briefcase, Part Number: USS-101-003BC; Quad Channel Satellite Simulator, Model Number: 4-Channel Satellite Simulator, Part Number: USS-101-400 | SMARTSAT, Inc. | Five versions of Satellite Simulator test equipment that simulate UHF satellite broadcasts | USML Category XI(a)(11) | 9/23/2025 |
| Drop-Glide Airframe (Live Variant, Training Variant, and Dummy Variant) with incorporated sensor window |
Orbital Research Inc. | Airframe for bomb, and two variants designed for training; some including a sensor window | CCL ECCNs 0A604.x (Live), 0A614.x (Training), 0A614.a (Dummy); USML Category IV(h)(22) sensor window |
9/23/2025 |
| Union - Flared Tube Bulk Restrictor, Part Number: JSFF28W04A039, Model Number: JSFF28 | Senior Operations, LLC | A flared bulkhead union restrictor | USML Category VIII(h)(1) | 9/23/2025 |
| GEN-1 Interceptor | Gilman Law PLLC (applicant)
Wild West Systems, Inc. (OEM) |
Small rocket projectile that can be launched from a handheld launcher and, in the future, mounted on a small UAV | USML Category IV(a)(5) Rocket projectile
USML Category IV(b)(2) Launcher when not integrated onto a UAV USML Category VIII(h)(6) Launcher when integrated onto a UAV |
9/30/2025 |
| 34mm Square Fiberoptic Faceplate, Part Number 102-1823 | Incom, Inc. | 34mm Square Fiberoptic Faceplate | USML Category XII(e)(1) | 9/30/2025 |
| CryoTEX 2000 Single Wall Cryogenic Pressure Vessel, Model V3X02S26-ABCDFJ | Prentex Alloy Fabricators, Inc | Storage container for extremely cold, pressurized liquids | Seek CCATS | 9/30/2025 |
| Fiber Optic Feedthrough, Part Number FFST12M10-PT- 131-28-005-LC-1K |
Princetel, Inc. | Device used to route fiber optic signals through sealed barriers | Seek a CCATS | 9/30/2025 |
| Tungsten Heavy Alloy (Tungsten 1.0" x 2.7" x 2.7" per ASTM B777, Class 1), (Part Number TUNG 1.0X2.7.2.7) | Elmet Technologies LLC | Tungsten alloy blocks | EAR99 | 9/30/2025 |
| Linerless Composite Overwrapped Vessel, Type V, 2.0 Liter Model Number: 117023, Part Number: 024 | Composite Technology Development Inc. | A pressure vessel that can store liquids and gases at high pressure | Seek a CCATS | 9/30/2025 |
| Alumionum Oxynitride (ALON) Ceramic Unfinished Products | Surmet Corp. | Unfinished, non-transparent, ceramic blanks | USML Category XIII(e)(4) | 9/30/2025 |
| Magpie, Versions 6.1 through 8.1 | Capella Space Corp. | Ground radio software that delivers data streams from satellites to ground station providers | Seek a CCATS | 9/30/2025 |
| Fiber-Fed Pulsed Plasma Thruster EELV Secondary Payload Adapter, Model FPPT-ESPA | CU Aerospace, LLC | Propulsion System for Small Satellites | Seek a CCATS | 9/30/2025 |
| Aerospace Friction Discs, Part Numbers CA50456, CA73363, and CA43486 | Moog Inc. | Aerospace friction discs | CA-73363 and CA-43486: USML Category VIII(h)(1)
CA-50456: RWA |
9/30/2025 |
| ZOE Intelligent Man Over Board AI-powered software | TEDGAR Consulting LLC | AI-enabled detection, tracking, and alerting software | USML Category XI(d) | 9/30/2025 |
| Common Releasable Munition Tail Kit, Version 1, Part Number DGM5-A-0011 | Orbital Research, Inc. | Tail kit providing a standardized interface for munitions dropped from Unmanned Aerial Vehicles (UAVs) | USML Category IV(h)(25) | 10/21/2025 |
| Modulair Magnetometer Survey System, Model Modulair v1 | Sokil | A system for conducting magnetic surveys for demining and unexploded ordnance | USML Category IV(c)(1) | 10/21/2025 |
| GRANITE DAGGER training course, v.GD 26-01 | Pareto Solutions LLC | Training course designed for U.S. and allied Special Forces | USML Category IX(e)(3) | 10/21/2025 |
| Integrated Anti-Drone System | Samel 90 | System to detect, identify, and interrupt UAVs | USML Category XI(a)(4)(iii) | 10/21/2025 |
| Instant Connect Enterprise Mobile Client, v3.7.0 | Instant Connect Software LLC | Mobile software application that configures and monitors the channels and battery level of radios described on the USML | USML Category XI(d) | 10/21/2025 |
| MK93 Gun Mount System, Part Number 13001175, NSN 1010-01-502-7547 | Special Tactical Services, LLC | Machine gun mount system | USML Category VII(g)(8) | 10/21/2025 |
| Absorptive Neutral Density Filter, Part Number: ANDV18162 | Andover Corporation | A neutral density filter that attenuates intensity levels of incoming light on a satellite spectrometer | Seek a CCATS | 10/21/2025 |
| Agile Power Batteries, Models AP-RF0 and AP-RF3 | Cornerstone Research Group, Inc | Portable, damage-tolerant, wearable rechargeable batteries that include an armored and unarmored variant | AP-RF0 – USML Category XI(a)(7)
AP-RF3 – USML Category X(a)(8) while in development; Category X(d)(1) thereafter |
10/21/2025 |
| Owl Talon with Data Diode Card, Model Numbers Owl Talon v3.X with either Owl Talon One, V7 or Torrent Data Diode Card; Part Numbers TALON-DDC-BA, TALONDDC-MP, TALON-DDC-ENT-B, TALON-DDCX2, TALON-V7-ENT-S, TALON-DDP-ENT-S, TALON-DDP-ENT-G, TALONDDP-ENT-P | Owl Cyber Defense Solutions, LLC | Combination of software and hardware that provides one-way data transfer and packet header deconstruction to mitigate the introduction of malicious code | Seek a CCATS | 10/21/2025 |
| MMLR-8 Multi-Mission Life Raft, Part Number 9-08-200 | The WING Group, DBA: The Patten Company | An 8-person life raft variant | USML Category VI(c) | 10/21/2025 |
| Drone Defeat Round, NSN 1305-00-096-3156 | Scott L. Braum & Associated, Ltd. | 12 gauge birdshot ammunition with tungsten projectiles | CCL ECCN 0A505.c (effective 9/15/2025) | 10/21/2025 |
| X-Band Radar Module | Umbra Lab, Inc. | A microwave instrument used in synthetic aperture radar (SAR) satellites | USML Category XV(e)(17) | 10/21/2025 |
| OMEGA Valve Article Family, Models: Mod. 1, Mod. 2, and Mod. 3 | J. Bennett Designs, LLC | Drop-in replacements for firearm gas blocks | CCL ECCN 0A501.x | 10/31/2025 |
| Reactor, Version 25.1.0 | Camgian Corporation | Decision automation software | USML Category XII(f) | 10/31/2025 |
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The U.S. Department of State Removed Cambodia From The ITAR At 22 CFR § 126.1
November 7, 2025: 90 Fed. Reg. 50489: The Department has published a final rule in the Federal Register updating the International Traffic in Arms Regulations (ITAR) to remove Cambodia from the list of countries in ITAR § 126.1. This rule codifies a policy announced on October 26, 2025.
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The Department Of State Revamped The DECCS Industry User Homepage
November 17, 2025: In support of section 3(e) of Executive Order 14268: Reforming Foreign Defense Sales to Improve Speed and Accountability, the Directorate of Defense Trade Controls has redesigned the State DECCS Industry User Homepage, effective November 13, 2025.
The updated homepage now includes the Industry User Dashboard, which provides industry users with key metrics, license status tracking, licensing officer information, and staffing agency insights in one convenient location. These enhancements are designed to improve efficiency and provide information at a glance.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events and https://www.federalregister.gov/documents/2025/04/15/2025-06464/reforming-foreign-defense-sales-to-improve-speed-and-accountability
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DDTC Frequently Asked Questions (FAQs)
Q: Are pre-contract activities undertaken in support of potential foreign assistance or sales program conducted by a company that owns the defense article considered brokering activity?
A: No. The company is acting on its own behalf. Ultimately the potential foreign assistance or sales program would potentially result in a secondary sales contract between the USG and one or more companies and when ITAR 129.5(a)(2)(i) an exemption from requirement for approval provisions are met such activity would be exempt from broker approval.
Q: If a consultant, who is registered as a broker, hires another consultant (independent contractor), do both entities need to be separately registered?
A: The consultant's business, which is registered as a broker subject to U.S. jurisdiction, who subsequently hires an independent contractor, would be able to have the contractor covered under the consultant's broker registration to the extent the contractor meets the regular employee definition under ITAR Section 120.64. This would mean that the contractor is in a long-term contractual relationship (one year or more), the contractor works at the U.S. company's facility and under the direction and control of the consultant, works full-time exclusively for the consultant, and executes a non-disclosure certification, etc. If the contractor does not meet the regular employee definition, is subject to U.S. jurisdiction, and will be performing brokering activity, then the contractor would need to have its own separate broker registration. If the contractor is not subject to U.S. jurisdiction per ITAR Section 129.2(a), the contractor would not have to register as a broker under the ITAR.
Q: Can brokering activities be included in the scope of an agreement?
A: Yes. When the activities taking place under an agreement include brokering activities, the agreement must clarify that brokering activities will occur. The “Whereas” clause for the party conducting brokering activities must state that the activity constitutes brokering activity. DDTC understands that in some cases, signatories may perceive a potential problem based on other nations’ definitions of the word “brokering.” In these situations, DDTC recommends that the ITAR definition of brokering be included in the body of the agreement. In the transmittal letter, applicants must identify the party(ies) that will conduct brokering (using the word “brokering”) under the TRANSACTION SUMMARY section.
Q: Can I get prior approval for brokering activities for another U.S. signatory to the agreement?
A: No. Approval for brokering activities must be requested by the broker conducting the activities, so the only entity that may obtain Prior Approval of brokering activities through an agreement is the U.S. applicant and any of its owned/controlled U.S. and foreign subsidiaries/ affiliates that are identified in the agreement. If the U.S. applicant is not the broker, Prior Approval cannot be obtained through the agreement. When requesting Prior Approval through an agreement, the submission must specifically request Prior Approval and specifically detail the defense articles and related technical data and provide all other required data in accordance with ITAR Part 129.
Q: If I am a registered broker may I apply for export licenses under my broker registration (K code)?
A: Brokers may not obtain export licenses. U.S. Brokers that need to obtain export licenses must submit an exporter registration and request export licenses using their exporter registration code.
Q: If residing overseas, is the foreign person employee considered a broker?
A: If truly employed by the U.S. person, the foreign person is NOT considered a broker when performing the U.S. person’s business (must be within the scope of the employment authorization) since he/she is a company employee.
Q: What are the Broker Report procedures?
A: Broker reports are due with broker renewal submissions (i.e., for persons already registered as brokers). The report must cover all brokering activity not the subject of a prior broker report. Broker reports must cover all brokering activity up to three months prior to the expiration of your broker registration. For example, if your registration expires at the end of November 30, 2013, then your broker report would cover the period from January 1st to August 31st. For subsequent years, your broker report would include a trailing 12 month period, e.g., September 1, 2013 to August 31, 2014.
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Department Of State, Department Of War And Department Of Commerce
The Departments Of State, War And Commerce Launched USXPORTS.Gov
November 21, 2025: The Department of State, in coordination with the Departments of War and Commerce, announced the launch of USXPORTS.gov, a unified portal for navigating to export license applications, developed in accordance with Section 3(e) of Executive Order 14268: Reforming Foreign Defense Sales to Improve Speed and Accountability.
USXPORTS.gov replaces ELISA, and introduces a publicly accessible, centralized case status search for Direct Commercial Sales export license requests. This unified interface enhances transparency in the export adjudication process, providing the defense industrial base and other users with greater visibility into the status of their applications.
By streamlining the application tracking process, USXPORTS.gov promotes efficiency across the defense export lifecycle, reducing administrative burdens and enabling the defense industrial base and other users to focus on advancing American security and prosperity by supporting defense partners.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events and https://www.federalregister.gov/documents/2025/04/15/2025-06464/reforming-foreign-defense-sales-to-improve-speed-and-accountability
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Department Of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress Of Potential FMS Sale To Denmark
November 12, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Denmark of AIM-9X Block II Tactical Missiles and related equipment for an estimated cost of $318.4 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Denmark has requested to buy up to three-hundred forty (340) AIM-9X Block II Sidewinder tactical missiles and up to thirty-four (34) AIM-9X Block II tactical guidance units. The following non-MDE items will also be included: training aids; weapon software; training; support equipment; spare and repair parts; publications and technical documentation; transportation; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The total estimated cost is $318.4 million.
The principal contractor will be RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To Taiwan
November 13, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Taipei Economic and Cultural Representative Office in the United States of Non-Standard Spare and Repair Parts and related equipment for an estimated cost of $330 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Taipei Economic and Cultural Representative Office in the United (TECRO) has requested to buy non-standard components, spare and repair parts, consumables and accessories, and repair and return support for F-16, C-130, and Indigenous Defense Fighter (IDF) aircraft; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $330 million.
The equipment will be transferred from U.S. Government stock. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To Iraq
November 13, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Iraq of Country Wide Repeater System and related equipment for an estimated cost of $100 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale.
The Government of Iraq has requested to buy Radio Access Points (RAP), handheld dismounted radios; radio base station systems; radio repeater systems; very high frequency vehicular radio systems; WiMax systems; intermediate power amplifier base station systems; intermediate power amplifier vehicular systems; Very Small Aperture Terminals; installation materials and kits; routers; switches; shelters; solar equipment; cameras and spare parts; personnel training and training equipment; studies and surveys; Contractor Logistics Support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support; repeater systems and installation kits; high-capacity line of sight systems; RAP infrastructure (shelter, solar, camera, and air conditioner); and IT components (router, switch, and rack) to support a Country Wide Repeater System; and other related elements of logistics and program support. The estimated total cost is $100 million.
The principal contractor will be L3Harris Corporation, located in Rochester, NY. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To Germany
November 14, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Germany of Standard Missile 6 Block I and Standard Missile 2 Block IIIC and related equipment for an estimated cost of $3.5 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Germany has requested to buy up to one hundred seventy three (173) Standard Missile 6 (SM-6) Block I missiles and up to five hundred seventy seven (577) Standard Missile 2 Block IIIC missiles, along with the non-MDE inclusion of MK 21 and MK 13 Vertical Launch System (VLS) missile transport, storage and launch canisters into which are installed SM-6 Block I and SM-2 Block IIIC missiles, respectively. The following additional non-MDE items will also be included: MK 21 Mod 3 Vertical Launch System (VLS) canisters; MK 13 Mod 1 VLS canisters; missile and support test equipment component parts; engineering, integration, and test (EI&T) materiel and support required to produce SM-6 Block I and SM-2 Block IIIC missiles; special test and handling equipment; training and training equipment aids; technical publications data; U.S. Government and contractor engineering, technical, and logistics support services; related studies and analysis support; and product life cycle sustainment support. The total estimated cost is $3.5 billion.
The principal contractor will be RTX Corporation, with locations in Camden, AR; Tucson, AZ; and Huntsville, AL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To Ukraine
November 18, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Ukraine of PATRIOT Air Defense System Sustainment and related equipment for an estimated cost of $105 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Ukraine has requested to buy sustainment related articles and services for the PATRIOT air defense system, including the upgrade of M901 launchers to M903 configuration; classified and unclassified prescribed load lists and authorized stockage lists for ground support equipment; other necessary services, ancillaries, spare parts, support, training, and accessories; and other related elements of logistics and program support. The estimated total cost is $105 million.
The principal contractors will be RTX Corporation, located in Arlington, VA, and Lockheed Martin, located in Bethesda, MD. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To India
November 19, 2025: The State Department has made a determination approving a possible Foreign Military Sale to India of Javelin Missile System and related equipment for an estimated cost of $45.7 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of India has requested to buy one hundred (100) FGM-148 Javelin rounds; one (1) Javelin FGM-148 missile, fly-to-buy; and twenty-five (25) Javelin Lightweight Command Launch Units (LwCLU) or Javelin Block 1 Command Launch Units (CLU). The following non-major defense equipment items will also be included: Javelin LwCLU or CLU Basic Skills Trainers; missile simulation rounds; battery coolant unit; interactive electronic technical manual; Javelin operator manuals; lifecycle support; physical security inspection; spare parts; system integration and check out; Security Assistance Management Directorate (SAMD) technical assistance; Tactical Aviation and Ground Munitions (TAGM) Project Office technical assistance; tool kits; training; Block 1 CLU refurbishment services; and other related elements of logistics and program support. The estimated total cost is $45.7 million.
The principal contractors will be a RTX Corporation/Lockheed Martin Javelin Joint Venture (JJV) of Orlando, Florida and Tucson, Arizona. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To India
November 19, 2025: The State Department has made a determination approving a possible Foreign Military Sale to India of Excalibur Projectiles and related equipment for an estimated cost of $47.1 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of India has requested to buy up to two hundred sixteen (216) M982A1 Excalibur tactical projectiles. The following non-MDE items will also be included: ancillary items; Portable Electronic Fire Control Systems (PEFCS) with Improved Platform Integration Kit (iPIK); primers; propellant charges; U.S. Government technical assistance; technical data; repair and return services; and other related elements of logistics and program support. The estimated total cost is $47.1 million.
The principal contractor will be RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress Of Potential FMS Sale To Japan
November 19, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Japan for munitions and related equipment for an estimated cost of $82 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Japan has requested to buy up to twenty-eight (28) GBU-53 Small Diameter Bombs-Increment II (SDB-II) all-up-rounds (AURs) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales case was valued at $81.04 million ($14.81 million in major defense equipment (MDE)). This notification is for a combined total of up to one-hundred-twenty (120) GBU-39 Small Diameter Bombs-Increment I (SDB-I); twenty-eight (28) GBU-53 SDB-IIs (AURs); thirty (30) KMU-556 Joint Direct Attack Munition (JDAM) tail kits for GBU-31; twenty (20) KMU-559 JDAM tail kits for GBU-32; twenty-four (24) KMU-572 JDAM tail kits for GBU-38; twenty-four (24) MK-82 500 lb general purpose (GP) bombs; thirty (30) MK-84 2,000 lb GP bombs; and twenty-one (21) BLU-110 1,000 lb GP bombs. The following non-MDE will also be included: FMU-139 joint programmable fuzes; DSU-38 laser sensors; practice bombs and bomb components; weapons and weapon support equipment; major modifications and maintenance support; training aids, devices, and spare parts; spare and repair parts, consumables, accessories, and repair and return support; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $82 million.
The principal contractors will be The Boeing Company, located in Arlington, VA; and RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4337497/japan-munitions
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DSCA Notifies Congress Of Potential FMS Sale To The United Kingdom
November 24, 2025: The State Department has made a determination approving a possible Foreign Military Sale to the Government of the United Kingdom of Navy Multiband Terminals and related equipment for an estimated cost of $200 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of the United Kingdom has requested to buy an additional six (6) Advanced Extremely High Frequency (AEHF) Navy Multiband Terminals (NMT) that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $41.02 million ($14.63 million in MDE), included two (2) AEHF NMTs. This notification is for a combined total of eight (8) AEHF NMTs. The following non-MDE items will also be included: KGV-136R communications security devices; communications equipment; submarine high data rate masts; ancillary equipment; containers; integration and test support; spare and repair parts; publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $200 million.
The principal contractor will be RTX Corporation, located in Arlington, VA. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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Department Of Commerce – Bureau Of Industry And Security (BIS)
BIS Suspended The 50% Affiliate Rule For One Year
November 11, 2025: The Bureau of Industry and Security (BIS) imposed a one-year suspension of the interim final rule, “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities,”. The suspension is set to end November 9, 2026, absent a future extension.
On September 30, 2025, BIS published the interim final rule, “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” Under the Affiliates Rule, any entity that is at least 50 percent owned directly or indirectly, individually or in the aggregate, by one or more entities on the Entity List, or by unlisted entities that are subject to license requirements or other restrictions based upon their ownership, is itself automatically subject to Entity List restrictions.
In this final rule, BIS imposes a one-year suspension of the Affiliates Rule. This rule will be implemented in two phases. The first phase, effective on November 10, 2025, and ending November 9, 2026, is a one-year suspension of the Affiliates Rule. BIS is temporarily suspending all changes previously made to the EAR by the Affiliates Rule during this period. In the second phase of this final rule, effective November 10, 2026 and extending indefinitely, the changes included in the Affiliates Rule that are removed in the first stage will be added back into the EAR. During the first phase of this final rule, BIS will continue to evaluate U.S. national security and foreign policy interests related to these non-listed foreign affiliates of listed entities.
This final rule adds back into the EAR effective November 10, 2026, the license requirements and related provisions from the Affiliates Rule. These are the same changes that are described as being removed in Sections I.C of this final rule. These changes to the EAR are the same as those described in the Affiliates Rule. See the Affiliates Rule for additional background information on the addition of these changes to the EAR.
https://public-inspection.federalregister.gov/2025-19846.pdf
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U.S. Census Bureau
Response Messages
November 20, 2025: When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning. It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations.
To help you take the appropriate action, here is guidance on how to address one of the most frequent Response Messages that were generated in the AES for the previous month.
Fatal Error Response Code: 539
Narrative: Shipping Weight Must be Zero for MOT
Severity: Fatal
Reason: The Mode of Transportation Code is not Vessel, Rail, Truck or Air and the Shipping Weight
is not reported as zeros.
Resolution: When the Mode of Transportation is other than Vessel, Rail, Truck or Air and the Export Information Code is not HH for household goods, the Shipping Weight must be zero.
Verify the Mode of Transportation and Shipping Weight, correct the shipment and resubmit.
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
November 4, 2025: Yana Leonova, 33, a Belorussian citizen most recently residing in Russia, was extradited from France on an indictment charging her with conspiring to violate the Export Control Reform Act, to commit smuggling, to commit money laundering, and to defraud the United States.
The indictment alleges that following Russia’s full-scale invasion of Ukraine in May 2022, Leonova – using co-conspirators located in the United States – procured and illicitly exported from the United States to Russia numerous avionics and other aircraft equipment. The exported items were for use on private aircraft operated by Leonova’s former employer a company identified on the U.S. Department of Commerce’s Entity List.
As part of the conspiracy, Leonova and her co-conspirators purchased the aircraft components from U.S.-based distributors. Using companies located in Armenia, the Maldives, and elsewhere, they then transshipped the components to Russia without the required licenses from the U.S. Department of Commerce.
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November 5, 2025: A federal jury has convicted Ji Wang, 63, of Painted Post, NY, of two counts of economic espionage, one count of theft of trade secrets, one count of attempted economic espionage, and one count of attempted theft of trade secrets.
Wang was born in China and immigrated to the United States in 1998 to work for Corning Incorporated. Between 2002 and 2007, Wang was assigned to work on a joint research and development project funded by the Defense Advanced Research Projects Agency (“DARPA”) and Corning. The goal of the 5-year, $11.4 million project was to develop optical fibers for high-powered lasers with military and commercial applications. DARPA and Corning aimed to increase the power of fiber lasers by more than a factor of 1000. DARPA sought to develop this technology to create laser weapons capable of shooting down drones and missiles.
On or about July 1, 2016, Wang stole hundreds of files that contained non-public data generated during the DARPA project, including trade-secret manufacturing technology that would have enabled him to fabricate all manner of specialty optical fibers, including for fiber lasers.
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November 20, 2025: Two U.S. citizens and two nationals of the People’s Republic of China (PRC)—all residing in the United States were charged with a conspiracy to illegally export cutting-edge NVIDIA Graphics Processing Units (GPUs), which have artificial intelligence (AI) applications, to the PRC.
Those arrested include Hon Ning Ho, aka “Mathew Ho,” a U.S. citizen born in Hong Kong, 34, residing in Tampa, Florida; Brian Curtis Raymond, U.S. citizen, 46, Huntsville, Alabama; Cham Li, aka “Tony Li,” PRC national, 38, San Leandro, California, and Jing Chen, aka “Harry Chen,” PRC national on F-1 nonimmigrant student visa, 45, Tampa, Florida. On Wednesday, November 19, 2025, Ho and Chen were arrested and appeared in court in the Middle District of Florida, while Raymond was arrested and appeared in the Northern District of Alabama.
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November 24, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a $4,677,552 penalty on an individual (“U.S. Person-1”) for violating OFAC sanctions on Russia and failing to comply with an OFAC subpoena. This action—which imposes the statutory maximum penalty—highlights the obligation of all U.S. persons, including individual investors and others in the real estate sector, to comply with OFAC’s sanctions regulations and orders. It results from OFAC’s proactive efforts to identify and prevent dealings in the blocked property of sanctioned individuals.
Between April 2023 and March 2024, this individual willfully dealt in residential real property owned by a blocked individual, including by mortgaging, renovating, and selling the property to an unwitting third party. The penalty amount reflects OFAC's determination that the violations were egregious and were not self-disclosed.
https://home.treasury.gov/news/press-releases/sb0323 and https://ofac.treasury.gov/recent-actions/20251124_33
Sanctions
Department of Commerce, Bureau of Industry and Security (BIS)
November 13, 2025: 90 Fed. Reg. 50938: On May 20, 2022, the then-Assistant Secretary of Commerce for Export Enforcement signed an order denying Rossiya Airline's export privileges for a period of 180 days on the ground that issuance of the order was necessary in the public interest to prevent an imminent violation of the Regulations. The order was issued ex parte pursuant to Section 766.24(a) of the Regulations and was effective upon issuance. The TDO was subsequently renewed in accordance with Section 766.24(d) of the Regulations on November 15, 2022. Subsequent renewal orders were issued on May 12, 2023, November 8, 2023, and November 5, 2024, respectively, and were also effective upon issuance.
BIS ordered the temporary denial of export privileges for Rossiya Airlines for one (1) year.
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November 26, 2025: 90 Fed. Reg. 54298: On September 4, 2024, in the U.S. District Court for the Middle District of Florida, Varun Maharajh, a/k/a Kelvin Singh (“Maharajh”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Maharajh was convicted of fraudulently and knowingly attempting to export and send firearms and ammunition from the United States to the United Kingdom and Trinidad and Tobago without required authorization. As a result of his convictions, the Court sentenced Maharajh to 84 months of imprisonment and three years of supervised release.
BIS denied Maharajh's export privileges under the Regulations for a period of ten (10) years from the date of Maharajh's conviction, until September 4, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Maharajh had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54293: On April 3, 2024, in the U.S. District Court for the Southern District of Texas, Sadir Arvizu Velazquez (“Velazquez”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Velazquez was convicted of fraudulently and knowingly attempting to export firearms from the United States to Mexico without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the Court sentenced Velazquez to 57 months of imprisonment and one year of supervised release.
BIS denied Velazquez's export privileges under the Regulations for a period of ten (10) years from the date of Velazquez's conviction, until April 3, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Velazquez had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54296: On July 31, 2024, in the U.S. District Court for the Southern District of Texas, Pedro Mascorro (“Mascorro”) was convicted of violating 18 U.S.C. 554. Specifically, Mascorro was convicted of smuggling firearms and ammunition from the United States to Mexico. As a result of his conviction, the Court sentenced Mascorro to 30 months in prison and three years of supervised release.
BIS denied Mascorro's export privileges under the Regulations for a period of seven (7) years from the date of Mascorro's conviction, until July 31, 2031. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Mascorro had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54294: On August 25, 2024, in the U.S. District Court for the Western District of Texas, Miguel Ocura-Arenas (“Ocura-Arenas”) was convicted of violating 18 U.S.C. 554. Specifically, Ocura-Arenas was convicted of convicted of knowingly and unlawfully facilitating the transportation and concealment of firearms and ammunition prior to exportation from the United States to Mexico, knowing that such items were intended for exportation from the United States without the required authorization. As a result of his conviction, the Court sentenced Ocura-Arenas to 48 months in prison and three years of supervised release.
BIS denied Ocura-Arenas' export privileges under the Regulations for a period of ten (10) years from the date of Ocura-Arenas' conviction, until August 25, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Ocura-Arenas had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54290: On September 12, 2024, in the U.S. District Court for the Southern District of Texas, Kevin Uriel Garza (“Garza”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Garza was convicted of fraudulently and knowingly receiving, concealing, buying, selling, or facilitating the transportation, concealment, or sale of ammunition prior to exportation from the United States, knowing that such items were intended for exportation from the United States without the required authorization. As a result of his conviction, the Court sentenced Garza to 37 months in prison and three years of supervised release.
BIS denied Garza 's export privileges under the Regulations for a period of ten (10) years from the date of Garza's conviction, until September 12, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Garza had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54292: On March 18, 2024, in the U.S. District Court for the Central District of California, Mohamed Daoud Ghacham (“Ghacham”), was convicted of violating 18 U.S.C. 371. Specifically, beginning no later than July 2011 and continuing to at least February 2021, Ghacham conspired with others to knowingly, willfully, and with the intent to defraud the United States make out and pass false, forged and fraudulent invoices and other documents and papers through a United States customhouse. As a result of his conviction, the Court sentenced Ghacham to 48 months of imprisonment and three years of supervised release.
BIS denied Ghacham's export privileges under the Regulations for a period of ten (10) years from the date of Ghacham's conviction, until March 18, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Ghacham had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54295: On July 12, 2024, in the U.S. District Court for the Southern District of Florida, Federick Joseph Bergmann, Jr., also known as Frederick Bergmann (“Bergmann”), was convicted of violating 18 U.S.C. 371. Specifically, Bergmann conspired to export various ballistic vests from the United States to Haiti without the required authorization. As a result of his conviction, the Court sentenced Bergmann to 108 months of imprisonment and three years of supervised release.
BIS denied Bergmann's export privileges under the Regulations for a period of ten (10) years from the date of Bergmann's conviction, until July 12, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Bergmann had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54297: On February 1, 2024, in the U.S. District Court for the Southern District of Texas, James Mwangangi Kiilu (“Kiilu”) was convicted of violating 18 U.S.C. 554 (Smuggling Goods from the United States). Specifically, Kiilu was convicted of fraudulently and knowingly attempting to export firearms from the United States to Mexico without the required authorization from the U.S. Department of Commerce. As a result of his conviction, the Court sentenced Kiilu to 52 months of imprisonment and three years of supervised release.
BIS denied Kiilu's export privileges under the Regulations for a period of ten (10) years from the date of Kiilu's conviction, until February 1, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Kiilu had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54291: On or about May 3, 2024, in the U.S. District Court for the Middle District of Florida, Antonio Jose Melean Reyes (“Reyes”) was convicted of violating 18 U.S.C. 554(a) (Smuggling Goods from the United States). Specifically, Reyes was convicted of smuggling firearms from the United States to Venezuela. As a result of his conviction, the Court sentenced Reyes to 72 months of imprisonment and three years of supervised release.
BIS denied Reyes' export privileges under the Regulations for a period of ten (10) years from the date of Reyes' conviction, until May 3, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Reyes had an interest at the time of his conviction.
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November 26, 2025: 90 Fed. Reg. 54297: On March 28, 2024, in the U.S. District Court for the Central District of California, Ghacham, Inc. (“Ghacham, Inc.”), was convicted of violating 18 U.S.C. 371. Specifically, beginning no later than July 2011 and continuing to at least February 2021, Ghacham, Inc. conspired with others to knowingly, willfully, and with the intent to defraud the United States make out and pass false, forged and fraudulent invoices and other documents and papers through a United States customhouse. As a result of Ghacham, Inc.'s conviction, the Court sentenced Ghacham, Inc. to five years of probation.
BIS denied Ghacham, Inc.'s export privileges under the Regulations for a period of ten (10) years from the date of Ghacham, Inc.'s conviction, until March 28, 2034. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Ghacham, Inc. had an interest at the time of its
conviction.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
November 4, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned eight individuals and two entities for their role in laundering funds derived from a variety of illicit Democratic People’s Republic of Korea (DPRK) schemes, including cybercrime and information technology (IT) worker fraud.
The following individuals have been added to OFAC's SDN List:
- Choe, Chun Pom, of North Korea;
- Han, Hong Gil, of North Korea;
- Ho, Jong Son, of North Korea and Japan;
- Ho, Yong Chol, of North Korea;
- Jang, Kuk Chol, of North Korea and Russia;
- Jong, Sung Hyok, of North Korea and Russia;
- Ri, Jin Hyok, of North Korea and China; and
- U, Yong Su, Dandong, of North Korea and China.
The following entities have been added to OFAC's SDN List:
- Korea Mangyongdae Computer Technology Corporation, of North Korea; and
- Ryujong Credit Bank, of North Korea.
https://home.treasury.gov/news/press-releases/sb0302 and https://ofac.treasury.gov/recent-actions/20251104
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November 4, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Belarus General License 12 "Authorizing Transactions Related to Certain Blocked Aircraft."
Belarus General License 12: All transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (BSR), related to the following aircraft are authorized:
(1) aircraft with tail number EW-001PA and serial number 33079;
(2) aircraft with tail number EW-001PB and serial number 33968; or
(3) aircraft with tail number EW-001PH and serial number 31835.
The authorization includes transactions related to the use of the aircraft by Alyaksandr Lukashenka or Foreign Limited Liability Company Slavkali, persons blocked pursuant to the BSR that have an interest in such aircraft. The aircraft identified in paragraph (a) of this general license are unblocked.
This general license does not authorize:
(1) The unblocking of any funds that were blocked on or before 12:01 a.m. eastern standard time, November 4, 2025; or
(2) Any transactions otherwise prohibited by the BSR, including transactions involving any person blocked pursuant to the BSR other than those persons and transactions described in this general license.
Note to General License No. 12. Nothing in this general license relieves any person from compliance with any other Federal laws or requirements of other Federal agencies, including the International Traffic in Arms Regulations (ITAR) administered by the Department of State and the Export Administration Regulations (EAR) administered by the Department of Commerce.
https://ofac.treasury.gov/recent-actions/20251104 and https://ofac.treasury.gov/media/934731/download?inline
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November 6, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action to support the disarmament of Hizballah by sanctioning individuals who facilitated funneling tens of millions of dollars from Iran to Hizballah in 2025, using exchange houses to take advantage of Lebanon’s cash-based financial sector. Hizballah uses these funds to support its paramilitary forces, rebuild its terrorist infrastructure, and resist the Lebanese government’s efforts to assert sovereign control over all Lebanese territory. Hizballah’s exploitation of money exchange companies and the cash economy to launder illicit funds threatens the integrity of the Lebanese financial system by blending terror financing with legitimate commerce.
The following individuals have been added to OFAC's SDN List:
- Jaber, Ossama, of Lebanon;
- Kasbar, Samer, of the United Arab Emirates and Syria; and
- QasirR, Ja'far Muhammad, of Lebanon.
https://home.treasury.gov/news/press-releases/sb0308 and https://ofac.treasury.gov/recent-actions/20251106
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November 10, 2025: The U.S. Department of State issued a suspension of mandatory Caesar Act sanctions based on the actions taken by the Syrian government following the fall of the al-Assad regime. The suspension of Caesar Act sanctions supports Syria’s efforts to rebuild its economy, restore ties with foreign partners, and foster prosperity and peace for all its citizens.
The Department of State, together with the Departments of the Treasury and Commerce, issued an advisory that describes for the public and private sector the sanctions and export controls relief provided by the U.S. government to date. The advisory also outlines permissible and non-permissible activities with Syria. A copy of the advisory can be found at the link listed below.
https://www.state.gov/releases/office-of-the-spokesperson/2025/11/sanctions-relief-that-gives-the-syrian-people-a-chance-at-greatness/ and https://ofac.treasury.gov/media/934736/download?inline
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November 12, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting 32 individuals and entities based in Iran, the United Arab Emirates (UAE), Türkiye, China, Hong Kong, India, Germany, and Ukraine that operate multiple procurement networks supporting Iran’s ballistic missile and unmanned aerial vehicle (UAV) production.
The following individuals have been added to OFAC's SDN List:
- Abtahi, Seyyed Ali, of Iran;
- Aung, Saw San, of Burma;
- Dolatabadi, Ehsan Mohaghegh, of Iran;
- Dolatkhah, Majid, of Iran;
- Hla, Sai Kyaw, of Burma;
- Klinge, Marco, of the United Arab Emirates and Germany;
- Ma, Jie, of China;
- Pahlavani Nejad, Saeed, of Iran;
- Qayumi, Vahid, of Iran;
- Ruhani, Seyyed Mohammad, of Iran;
- Sawang, Chamu, of Thailand;
- Shafiei, Batoul, of Iran;
- Steel, Saw, of Burma;
- Tabibi, Bahram, of Iran;
- Turanlu, Hosein Sayyadi, of Iran; and
- Win, Saw Sein, of Burma.
The following entities have been added to OFAC's SDN List:
- Arkedya Gida Tekstil Dis Ticaret Sanayi Limited Sirketi, of Turkey;
- Artas Gumrukleme Ithalat Ihracat Sinir Ticareti Tekstil Gida Ve Sanayi Ticaret Limited Sirketi, of Turkey;
- Democratic Karen Benevolent Army, of Burma;
- Ekofera LLC, of the Ukraine;
- Eva Handelsgesellschaft UG, of Germany;
- Farmlane Private Limited, of India;
- Furqan Novin Pars Manufacturing And Commercial Industries, of Iran;
- GK Imperativ Ukraina LLC, of the Ukraine;
- Hin Yun Trading Company Limited, of China;
- Intro Oto Yedek Parca Ithalat Ihracat Ticaret Ve Sanayi Limited Sirketi, of Turkey;
- Iranian Baspar Puya Company, of Iran;
- Loris Turizm Organizasyon Ithalat Ve Ihracat Limited Sirketi, of Turkey;
- Mvm Amici Trading LLC, of the United Arab Emirates;
- Own Ucar Gida Insaat Sanayi Ve Ticaret Limited Sirketi, of Turkey;
- Ozkam Nakliyat Petrol Ithalat Ihracat Sanayi Ticaret Limited Sirketi, of Turkey;
- Pars Navandishan Artificial Intelligence Projects Company, of Iran;
- Qian Xi Long Trading Co Limited, of China;
- Royal Yapi Insaat Emlak Gida Ve Tekstil Urunleri Turizm Sanayi Dis Ticaret Limited Sirketi, of Turkey;
- Trans Asia International Holding Group Thailand Company Limited, of Thailand;
- Troth Star Company Limited, of Burma;
- Vahid Ghayoumy Goods Wholesalers LLC, of the United Arab Emirates;
- Yiren Zhuang Trading Co Limited, of China;
- Yiwu City Xianma Import And Export Co Ltd, of China; and
- Zagros Shimi Fars Manufacturing Industries Company, of Iran.
https://home.treasury.gov/news/press-releases/sb0313 and https://ofac.treasury.gov/recent-actions/20251112
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November 12, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Democratic Karen Benevolent Army (DKBA), a Burmese armed group, along with four of its senior leaders, for supporting cyber scam centers in Burma that target Americans using fraudulent investment schemes. OFAC is also designated Trans Asia International Holding Group Thailand Company Limited (Trans Asia), Troth Star Company Limited (Troth Star), and Thai national Chamu Sawang, who are linked to Chinese organized crime and have worked with the DKBA and other armed groups to develop these scam centers. The revenue generated by scam center workers—who are often themselves victims of human trafficking—supports organized crime and allows the DKBA to finance its harmful activities.
https://home.treasury.gov/news/press-releases/sb0312
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November 13, 2025: The Department of State and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Antifa Ost, Informal Anarchist Federation/International Revolutionary Front, Armed Proletarian Justice, and Revolutionary Class Self-Defense as Specially Designated Global Terrorists (SDGTs) and the intent to designate all four groups as Foreign Terrorist Organizations (FTOs), effective November 20, 2025.
The following entities have been added to OFAC's SDN List:
- Antifa OST, of Germany;
- Armed Proletarian Justice, of Greece;
- Informal Anarchist Federation/International Revolutionary Front, of Italy; and
- Revolutionary Class Self-Defense, of Greece.
https://www.state.gov/releases/office-of-the-spokesperson/2025/11/designations-of-antifa-ost-and-three-other-violent-antifa-groups/ and https://ofac.treasury.gov/recent-actions/20251113_33
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November 13, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) joined the Government of Mexico in targeting the Hysa Organized Crime Group and numerous Mexico-based gambling establishments involved in cartel-related money laundering and a slew of other criminal activities across Mexico and Europe. This coordinated action was the result of recent U.S.-Mexico commitments—secured during Treasury Under Secretary for Terrorism and Financial Intelligence John K. Hurley’s trip—to work together more closely to combat narcotrafficking and related financial crime by Mexico-based drug cartels and other groups.
The following individuals have been added to OFAC's SDN List:
- Baku, Eselda, of Mexico;
- Hysa, Arben, of Mexico;
- Hysa, Fabjon, of Canada and Albania;
- Hysa, Fatos, of Albania;
- Hysa, Luftar, of Canada;
- Hysa, Ramiz, Rosarito, of Mexico; and
- Lopez Lopez, Gilberto, of Mexico.
The following entities have been added to OFAC's SDN List:
- Bliri S.A. DE C.V., of Mexico;
- Cucina Del Porto S.A. DE C.V., of Mexico;
- Diversiones Los Mochis S.A. DE C.V., of Mexico;
- El Arte De Cocinas Y Beber S.A. DE C.V., of Mexico;
- Entretenimiento Palermo S.A. DE C.V., of Mexico;
- Entretenimiento Villahermosa S.A. DE C.V., of Mexico;
- Entretenimiento Y Espectaculos B.C. S.A. DE C.V., of Mexico;
- Grupo Internacional Canhysamex S.A. DE C.V., of Mexico;
- H Hidrocarburos S.A. DE C.V., of Mexico;
- Hysa Forwarders S.A. DE C.V., of Mexico;
- Hysa Holdings Inc, of Canada;
- Hysa Organized Crime Group, of Mexico;
- Lh Pro-Gaming S.A. DE C.V., of Mexico;
- Lh Rental S.A. DE C.V., of Mexico;
- Operadora Alejil S.A. DE C.V., of Mexico;
- Operadora De Empresas Lh S.A. DE C.V., of Mexico;
- Procesadora De Alimentos Hs S.A. DE C.V., of Mexico;
- Rosetta Gaming Inc, of Canada;
- Rosetta Gaming S.A. DE C.V., of Mexico; and
- Rosetta Gaming Spolka Z Ograniczona Odpowiedzialnoscia, of Poland.
https://home.treasury.gov/news/press-releases/sb0315 and https://ofac.treasury.gov/recent-actions/20251113
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November 14, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 124B, "Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium, Tengizchevroil, and Karachaganak Projects;" Russia-related General License 128A, "Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia;" Russia-related General License 130, "Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria;" and Russia-related General License 131, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities."
Russia-related General License 124B: All transactions prohibited by the determination of January 10, 2025 made pursuant to section 1(a)(ii) of Executive Order (E.O.) 14071 (“Prohibition on Petroleum Services”) that are related to the operation of the Caspian Pipeline Consortium, Tengizchevroil, or Karachaganak projects are authorized. All transactions prohibited by E.O. 14024 involving one or more of the following blocked persons that are related to the operation of the Caspian Pipeline Consortium, Tengizchevroil, or Karachaganak projects are authorized: (1) Rosneft Oil Company; (2) Public Joint-Stock Company Oil Company Lukoil; or (3) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
This general license does not authorize: (1) Any transactions for the sale, disposition, or transfer of any interest in the Caspian Pipeline Consortium, Tengizchevroil, or Karachaganak projects; or (2) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, other than the blocked persons described above, unless separately authorized.
Effective November 14, 2025, General License No. 124A, dated October 22, 2025, is replaced and superseded in its entirety by this General License No. 124B.
Russia-related General License 128A: All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside of the Russian Federation (“Lukoil Retail Service Stations”), are authorized through 12:01 a.m. eastern standard time, December 13, 2025, provided that any payment, directly or indirectly, to a blocked person—other than blocked Lukoil Retail Service Stations—is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).
Note: For the purpose of this general license, the term “Lukoil Retail Service Stations” means physical retail service stations located outside the Russian Federation and in existence on or before October 22, 2025 in which (1) Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) has an interest, or (2) any entity in which Lukoil owns, directly or indirectly, a 50 percent or greater interest, has an interest.
This general license does not authorize: (1) Any transactions prohibited by Directive 2 under E.O. 14024, Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions; (2) Any transactions prohibited by Directive 4 under E.O. 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation; or (3) Any transactions otherwise prohibited by the RuHSR, unless separately authorized.
Effective November 14, 2025, General License No. 128, dated October 22, 2025, is replaced and superseded in its entirety by this General License No. 128A.
Russia-related General License 130: All transactions prohibited by Executive Order (E.O.) 14024 involving the following entities are authorized through 12:01 a.m. eastern daylight time, April 29, 2026: (1) Lukoil Neftohim Burgas JSC; (2) Lukoil Bulgaria EOOD; (3) Lukoil Aviation Bulgaria EOOD; (4) Lukoil Bulgaria Bunker EOOD; or (5) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
This general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR, including any other blocked affiliates of Public Joint-Stock Company Oil Company Lukoil, other than the blocked persons described above in this general license, unless separately authorized.
Russia-related General License 131: All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the negotiation of and entry into contracts with Public Joint-Stock Company Oil Company Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “LIG Entities”) are authorized through 12:01 a.m. eastern standard time, December 13, 2025, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control (“contingent contracts”).
Note: for purposes of this general license, the term “contingent contracts” includes executory contracts, executory pro forma invoices, agreements in principle, executory offers capable of acceptance such as bids or proposals in response to public tenders, binding memoranda of understanding, or any other similar agreement.
All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG Entities are authorized through 12:01 a.m. eastern standard time, December 13, 2025, provided that any payment, directly or indirectly, to LIG Entities or any other blocked person is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).
This general license does not authorize: (1) The unblocking of any property blocked pursuant to any part of 31 CFR chapter V; or (2) Any transactions otherwise prohibited by the RuHSR, including transactions involving any person blocked pursuant to the RuHSR, other than blocked persons described in paragraph (a) of this general license, unless separately authorized.
https://ofac.treasury.gov/recent-actions/20251114 and https://ofac.treasury.gov/media/934746/download?inline and https://ofac.treasury.gov/media/934751/download?inline and https://ofac.treasury.gov/media/934756/download?inline and
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November 19, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Ryan James Wedding (Wedding), alongside nine individuals and nine entities closely associated with him. Wedding, a former Olympic snowboarder for Team Canada, is one of the Federal Bureau of Investigation’s (FBI) Ten Most Wanted Fugitives. He is an extremely violent criminal believed to be responsible for the murder of numerous people abroad, including U.S. citizens. Wedding remains a fugitive from justice, currently hiding in Mexico, where he continues to direct drug trafficking, murder, and other serious criminal activities.
The following individuals have been added to OFAC's SDN List:
- Acuna Macias, Daniela Alejandra, of Mexico and Colombia;
- Castillo Moreno, Miryam Andrea, of Mexico;
- Diana, Cristian, Isernia, of Italy;
- Fallon, John Anthony, of the United Kingdom;
- Paradkar, Deepak Balwant, of Canada;
- Sokolovski, Rolan, of Canada;
- Tiepolo, Gianluca, of Italy;
- Valoyes Florez, Carmen Yelinet, of Mexico and Colombia;
- Vazquez Alvarado, Edgar Aaron, of Mexico;
- Wedding, Ryan James, of Mexico and Canada.
The following entities have been added to OFAC's SDN List:
- 2351885 Ontario Inc, of Canada;
- Grupo Ares Imperial S. De R.L. DE C.V., of Mexico;
- Grupo Rvg Combustibles S.A. DE C.V., of Mexico;
- LMJ Trading LTD, of the United Kingdom;
- Made In Italy Motorcycles Limited, of the United Kingdom;
- Stile Italiano S.R.L., of Italy;
- TMR LTD, of the United Kingdom;
- VRG Energeticos S.A. DE C.V., of Mexico;
- Windrose Tactical Solutions S.R.L.S., of Italy.
https://home.treasury.gov/news/press-releases/sb0320 and https://ofac.treasury.gov/recent-actions/20251119_33
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November 19, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC), Australia’s Department of Foreign Affairs and Trade, and the United Kingdom’s Foreign Commonwealth and Development Office announced coordinated sanctions targeting Media Land, a Russia-based bulletproof hosting (BPH) service provider, for its role in supporting ransomware operations and other forms of cybercrime. OFAC designated three members of Media Land’s leadership team and three of its sister companies in coordination with the Federal Bureau of Investigation.
BPH service providers sell access to specialized servers and other computer infrastructure specifically designed to evade detection and defy law enforcement efforts to disrupt malicious cyber activities.
In addition, OFAC and the United Kingdom designated Hypercore Ltd., a front company of Aeza Group LLC (Aeza Group), a BPH service provider designated by OFAC earlier this year. OFAC, in coordination with its UK partners, is also designating two additional individuals and two entities that have led, materially supported, or acted for Aeza Group.
The following individuals have been added to OFAC's SDN List:
- Makarov, Maksim Vladimirovich, of Russia;
- Pankova, Yulia Vladimirovna, of Russia;
- Volosovik, Aleksandr Aleksandrovich, of Russia;
- Zakirov, Ilya Vladislavovich, of Russia; and
- Zatolokin, Kirill Andreevich, of Russia.
The following entities have been added to OFAC's SDN List:
- Data Center Kirishi Limited Liability Company, of Russia;
- Datavice MCHJ, of Uzbekistan;
- Hypercore LTD, of the United Kingdom;
- Media Land Technology Limited Liability Company, of Russia;
- Media Land, LLC, of Russia;
- Cloud, LLC, of Russia and China; and
- Smart Digital Ideas DOO, of Serbia.
https://home.treasury.gov/news/press-releases/sb0319 and https://ofac.treasury.gov/recent-actions/20251119
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November 20, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of front companies and shipping facilitators that bankroll the Iranian armed forces by selling crude oil. Following its defeat in the 12-Day War with Israel, Iran’s military has increasingly come to rely on the sale of Iranian crude oil to supplement its annual budget and finance the rebuilding of its depleted forces.
OFAC also targeted six vessels, expanding sanctions on the shadow fleet of tankers Iran relies on to transport its oil exports to market.
Lastly, OFAC took further action against Iranian airline Mahan Air, which has worked closely with the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to arm and supply Iran-backed terrorist groups throughout the Middle East. Mahan Air played a key role in the Iranian regime’s efforts to arm the now-deposed regime of Syrian dictator Bashar al-Assad.
The following individuals have been added to OFAC's SDN List:
- Bin Ahmad, Fadzlon, of Singapore;
- Bin Fadzlon, Muhammad Danial, of Singapore;
- Ghaedi, Ahmad, of the United Arab Emirates;
- Heidari, Hamidreza, of Iran;
- Heidari, Reza, of Iran;
- Hosseini, Sayyed Mojtaba, of Iran;
- Jahromi, Mohammad Reza Moaref, of Iran and Canada;
- Madzharska, Penka Ivanova, of Bulgaria;
- Maghfoori, Mohammad Mahdi, of Iran;
- Moloudi, Mohammad, of Iran;
- Namakshenas, Reza, of Iran;
- Sayed, Zair Husain Iqbal Husain, of India;
- Sayed, Zulfikar Hussain Rizvi, of India; and
- Zahabi, Kaveh Rostami, of Iran.
The following entities have been added to OFAC's SDN List:
- Alsafeenah Althahabya Ship And Boats Spare Parts And Components Trading L.L.C., of the United Arab Emirates;
- Altomare S.A., of Greece;
- ANBO Shipping PTE. LTD., of Singapore;
- Arkadia Maritime Incorporated, of the Marshall Islands;
- Bonjoure Commodity F.Z.E., of the United Arab Emirates;
- Bonjoure International FZCO, of the United Arab Emirates;
- BPT Berlin Petroleum Trading GMBH, of Germany;
- Corfu Maritime And Trading S.A., of Panama;
- Deep Current Shipping L.L.C. of the United Arab Emirates;
- Erst Group LTD, of the Seychelles;
- Loire Shipping Inc., of Panama;
- Luan Bird Shipping Service L.L.C., of the United Arab Emirates;
- Macka Invest Company Limited, of Gambia;
- Mars Investment L.L.C., of the United Arab Emirates;
- Moon Line Plastics And Raw Materials Trading L.L.C., of the United Arab Emirates;
- Pioneer Tankers Marine Incorporated, of Liberia;
- RN Ship Management Private Limited, of India;
- Serifos Maritime And Trading S.A., of Panama;
- Shandong Independent Energy Trading DMCC, of the United Arab Emirates;
- Strasselink PTE. LTD., of Singapore;
- Thasos Maritime And Trading S.A., of Panama;
- Tilos Maritime And Trading S.A., of Panama;
- TR6 Petro India LLP, of India; and
- Yazd International Airways Company, of Iran.
The following vessels have been added to OFAC's SDN List:
- Al Siddeeq; Vessel Registration Identification IMO 9312509; MMSI 352005939;
- Aquaris; Vessel Registration Identification IMO 9251822; MMSI 352003040;
- Ava 10; Vessel Registration Identification IMO 9247986; MMSI 620999909;
- Bodhi; Vessel Registration Identification IMO 9144782; MMSI 613003728;
- Gas Athena; Vessel Registration Identification IMO 9267950; MMSI 374041000;
- Kaisa I; Vessel Registration Identification IMO 9038763; MMSI 374043000;
- Kallista; Vessel Registration Identification IMO 9411965; MMSI 352001127;
- Nexo; Vessel Registration Identification IMO 9014456; MMSI 629009304;
- Pioneer Sam; Vessel Registration Identification IMO 9232620; MMSI 511100620;
- Tusitala; Vessel Registration Identification IMO 8912546; MMSI 629009404.
The following aircraft have been added to OFAC's SDN List:
- EP-MEB; Aircraft Manufacture Date 1997; Aircraft Model Avro RJ85; Aircraft Operator MAHAN AIR; Aircraft Manufacturer's Serial Number (MSN) E2319; Aircraft Tail Number EP-MEB;
- EP-MEH; Aircraft Manufacture Date 1992; Aircraft Model Fokker 50; Aircraft Operator MAHAN AIR; Aircraft Manufacturer's Serial Number (MSN) 20263; Aircraft Tail Number EP-MEH;
- EP-MJA; Aircraft Manufacture Date 1995; Aircraft Model A340-200; Aircraft Operator MAHAN AIR; Aircraft Manufacturer's Serial Number (MSN) 075; Aircraft Tail Number EP-MJA;
- EP-MJE; Aircraft Manufacture Date 1999; Aircraft Model A340-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer's Serial Number (MSN) 270; Aircraft Tail Number EP-MJE;
- EP-MJF; Aircraft Manufacture Date 2000; Aircraft Model A340-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer's Serial Number (MSN) 331; Aircraft Tail Number EP-MJF;
- EP-MJG; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-300; Aircraft Operator Mahan Air; Aircraft Manufacturer's Serial Number (MSN) 474; Aircraft Tail Number EP-MJG; and
- EP-MMU; Aircraft Manufacture Date 2008; Aircraft Model A340-600; Aircraft Operator MAHAN AIR; Aircraft Manufacturer's Serial Number (MSN) 933; Aircraft Tail Number EP-MMU.
https://home.treasury.gov/news/press-releases/sb0322 and https://ofac.treasury.gov/recent-actions/20251120
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November 21, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 132, "Authorizing Certain Transactions Involving Paks II Civil Nuclear Power Plant."
Russia-related General License 132: All transactions prohibited by Executive Order (E.O.) 14024 involving the Paks II civil nuclear power plant project in Hungary (Paks II), including Paks II. Nuclear Power Plant Private Limited Company, or any successor project to the Paks II, that involve one or more of the following entities are authorized: (1) Gazprombank Joint Stock Company; (2) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (3) Public Joint Stock Company Bank Financial Corporation Otkritie; (4) Sovcombank Open Joint Stock Company; (5) Public Joint Stock Company Sberbank of Russia; (6) VTB Bank Public Joint Stock Company; (7) Joint Stock Company Alfa-Bank; (8) Public Joint Stock Company Rosbank; (9) Bank Zenit Public Joint Stock Company; (10) Bank Saint-Petersburg Public Joint Stock Company; (11) National Clearing Center (NCC); (12) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or (13) the Central Bank of the Russian Federation.
This general license does not authorize: (1) The opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity subject to Directive 2 under E.O. 14024, Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions; (2) Any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance; or (3) Any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to the RuHSR other than the blocked persons described in this general license, unless separately authorized.
https://ofac.treasury.gov/recent-actions/20251121 and https://ofac.treasury.gov/media/934776/download?inline
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U.S. Department of State
November 16, 2025: The Department of State intends to designate Cartel de los Soles as a Foreign Terrorist Organization (FTO), effective November 24, 2025. Based in Venezuela, the Cartel de los Soles is headed by Nicolás Maduro and other high-ranking individuals of the illegitimate Maduro regime who have corrupted Venezuela’s military, intelligence, legislature, and judiciary. Neither Maduro nor his cronies represent Venezuela’s legitimate government. Cartel de los Soles by and with other designated FTOs including Tren de Aragua and the Sinaloa Cartel are responsible for terrorist violence throughout our hemisphere as well as for trafficking drugs into the United States and Europe.
The United States will continue using all available tools to protect its national security interests and deny funding and resources to narco-terrorists.