This newsletter is a listing of the latest changes in export control regulations through January 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
Prioritizing the Warfighter in Defense Contracting
January 7, 2026: 91 Fed. Reg. 1377: On January 7, 2026, Executive Order 14372, titled “Prioritizing the Warfighter in Defense Contracting,” was issued. The order asserted that parts of the U.S. defense industrial base have focused excessively on shareholder returns—such as stock buybacks and dividends—at the expense of production capacity, timely delivery, and military readiness. While acknowledging that the United States produces highly capable weapons systems, the order emphasizes that insufficient speed and scale of production now pose a national security risk.
To address this, the order directs the federal government to reorient defense procurement around warfighter needs, making on‑time, on‑budget delivery and investment in production capacity core priorities. Major defense contractors that underperform on existing contracts are barred from issuing dividends or repurchasing stock until performance improves. The Secretary of Defense is tasked with reviewing contractor performance, notifying firms of deficiencies, and—where permitted by law—requiring board‑approved remediation plans, signaling a shift toward stricter oversight and enforcement in defense contracting.
https://www.whitehouse.gov/presidential-actions/2026/01/prioritizing-the-warfighter-in-defense-contracting/ and https://www.federalregister.gov/documents/2026/01/13/2026-00554/prioritizing-the-warfighter-in-defense-contracting
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Adjusting Imports of Semiconductors, Semiconductor Manufacturing Equipment, and Their Derivative Products Into the United States
January 14, 2026: 91 Fed. Reg. 2443: Issued on January 14, 2026, this presidential proclamation—Proclamation 11002, determined, following a Section 232 investigation by the Secretary of Commerce, that imports of semiconductors, semiconductor manufacturing equipment, and their derivative products threaten to impair U.S. national security due to inadequate domestic capacity and reliance on foreign supply chains. Acting under the Trade Expansion Act of 1962, the President directs measures to adjust imports, including targeted tariffs (25% ad valorem) on specified advanced semiconductors and certain derivatives effective January 15, 2026, with defined end‑use exclusions (e.g., data centers, R&D, repairs/replacements) and implementation guidance coordinated with CBP. The proclamation underscores semiconductors’ critical role in defense systems, AI, and all 16 critical infrastructure sectors, and frames the action as part of a broader strategy to strengthen domestic manufacturing and supply‑chain resilience.
https://www.whitehouse.gov/presidential-actions/2026/01/adjusting-imports-of-semiconductors-semiconductor-manufacturing-equipment-and-their-derivative-products-into-the-united-states/ and https://www.federalregister.gov/documents/2026/01/20/2026-01052/adjusting-imports-of-semiconductors-semiconductor-manufacturing-equipment-and-their-derivative
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January 14, 2026: On October 24, 2025, the Secretary of Commerce (Secretary) transmitted to the President a report on the investigation into the effects of imports of processed critical minerals and their derivative products (PCMDPs) on the national security of the United States under section 232 of the Trade Expansion Act of 1962, as amended, 19 U.S.C. 1862 (section 232). Based on the facts considered in that investigation, which took into account the close relation of the economic welfare of the Nation to the national security and other relevant factors, see 19 U.S.C. 1862(d), the Secretary found and advised of his opinion that PCMDPs are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States.
In light of these findings, the Secretary recommended a range of actions, including actions to adjust the imports of PCMDPs so that such imports will not threaten to impair the national security. For example, the Secretary recommended that the negotiation of agreements with foreign nations to ensure the United States has adequate critical mineral supplies and to mitigate the supply chain vulnerabilities as quickly as possible. The Secretary also suggested that it may be appropriate to impose import restrictions, such as tariffs, if satisfactory agreements are not reached in a timely manner.
After considering the Secretary’s report, the factors in section 232(d) (19 U.S.C. 1862(d)), and other relevant factors and information, the President concurs with the Secretary’s finding that PCMDPs are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States. In the Presidents judgment, and in light of the Secretary’s report, the factors in section 232(d) (19 U.S.C. 1862(d)), and other relevant factors and information, the President determined that it is necessary and appropriate to enter into negotiations with trading partners to adjust the imports of PCMDPs so that such imports will not threaten to impair the national security of the United States. Depending on the outcome of such negotiations, the President may consider alternative remedies in the future, including minimum import prices for specific types of critical minerals. The President has directed the Secretary and the United States Trade Representative (Trade Representative) to jointly pursue negotiation of agreements or continue any current negotiations of agreements, such as agreements contemplated in section 232(c)(3)(A)(i) (19 U.S.C. 1862(c)(3)(A)(i)), to address the threatened impairment of the national security with respect to PCMDPs. Depending on the status or outcome of those negotiations, the President may take other measures to adjust the imports of PCMDPs to address the threat to the national security found in this proclamation.
Section 232 authorizes the President to adjust the imports of an article and its derivatives that are being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security so that such imports will not threaten to impair the national security. Section 232 includes the authority to adopt and carry out a plan of action, with adjustments over time, to address the national security threat. That initial plan of action may include negotiations of agreements with foreign trading partners along with other measures to adjust imports to address the national security threat. If action under section 232 includes the negotiation of an agreement, such as one contemplated in section 232(c)(3)(A)(i) (19 U.S.C. 1862(c)(3)(A)(i)), the President may also take other actions he deems necessary to adjust imports and eliminate the threat to the national security, including if such an agreement is not entered into within 180 days of the date of this proclamation or is not being carried out or is ineffective. See 19 U.S.C. 1862(c)(3)(A).
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Department of State, Directorate of Defense Trade Controls (DDTC)
DDTC Announces Enrollment for the 2026 DECCS User Group
January 12, 2026: What is the DECCS User Group?
The Defense Export Controls and Compliance System (DECCS) User Group (DUG) provides a forum for industry users to share feedback on DECCS directly with the Directorate of Defense Trade Controls (DDTC). The group fosters active, ongoing communication between DECCS users and DDTC to support system improvements.
DUG members will have the opportunity to:
- Identify and communicate functional and technical challenges encountered in DECCS; and
- Provide input on future DECCS enhancements and system support initiatives.
Who should apply?
DDTC seeks up to 50 industry volunteers including representatives from companies, government agencies, and third-party organizations who are enrolled in DECCS and can offer an end-user perspective. Both U.S.-based and international members are welcome.
Time Commitment:
- DDTC plans to engage with DUG members to test new updates when system functionality is ready for testing; it is anticipated that total time commitment will not exceed 20 hours over the calendar year;
- Participation in DUG Spring and Fall meetings (dates to be confirmed); and
- The DUG term lasts one calendar year.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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Approval for Cluster Munition – Republic of Korea
January 14, 2026: 91 Fed. Reg. 1661: This notice published a Presidential Memorandum dated December 26, 2025, in which the President delegated authority to the Secretary of State to authorize up to $25.9 million in sales of cluster munitions technology to the Republic of Korea under the Arms Export Control Act. The delegation was issued under the President’s constitutional and statutory authority, including 3 U.S.C. § 301, and directed that the memorandum be published in the Federal Register, making the delegation effective upon publication.
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60‑Day Notice of Proposed Information Collection: Request for Commodity Jurisdiction Determination
January 15, 2026: 91 Fed. Reg. 1852: This notice announces a request for public comment on the Department of State’s proposed renewal of the information collection supporting the Commodity Jurisdiction (CJ) determination process, which determines whether an item or service is subject to the U.S. Munitions List and ITAR. The collection uses Form DS‑4076, is administered by DDTC, and assists exporters in determining the appropriate export control authority. The notice provides a 60‑day comment period, ending March 16, 2026, prior to submission to OMB for approval.
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Delegation to the Under Secretary of State for Arms Control and International Security for Country Reports on Terrorism
January 20, 2026: 91 Fed. Reg. 2415: This notice announced the delegation of authority (Delegation No. 606) by the Secretary of State to the Under Secretary of State for Arms Control and International Security to carry out the functions and authorities related to the annual Country Reports on Terrorism (CRT) required under section 140 of the Foreign Relations Authorization Act, Fiscal Years 1988 and 1989. The delegation allows the Under Secretary to prepare and oversee terrorism reporting while preserving the authority of the Secretary of State and senior Department leadership to exercise these functions concurrently. The delegation was signed on September 11, 2025, and published in the Federal Register on January 20, 2026.
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60‑Day Notice of Proposed Information Collection: Request To Change End‑User, End‑Use and/or Destination
January 21, 2026: 91 Fed. Reg. 2582: This notice seeks public comment on the Department of State’s request for OMB approval to extend an existing information collection used by the Directorate of Defense Trade Controls (DDTC) to process requests to change the end‑user, end‑use, or destination of defense articles authorized under licenses or open general licenses. The collection, associated with Form DS‑6004, is mandatory, supports ITAR compliance, and is intended to ensure the United States maintains control over downstream transfers of controlled defense items. Comments are due by March 23, 2026.
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60‑Day Notice of Proposed Information Collection: Technology Security/Clearance Plans and Screening Records
January 21, 2026: 91 Fed. Reg. 2583: This notice invites public comment on a proposed extension of an information collection supporting Technology Security/Clearance Plans (TSCPs), screening records, and non‑disclosure agreements required under 22 CFR § 126.18 (an exemption in the ITAR for foreign persons/entities to use in connection with their employment of dual and third country nationals). Administered by DDTC, the collection applies to businesses and nonprofit organizations engaged in certain controlled defense activities and is used to mitigate foreign national access risks associated with defense exports. The proposed collection is mandatory, with an estimated 100,000 annual burden hours, and comments are due by March 23, 2026.
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Major Non-NATO Ally Designations
January 23, 2026: 91 Fed. Reg. 3019: Republic of Peru; Designated a Major Non‑NATO Ally of the United States under section 517 of the Foreign Assistance Act (22 U.S.C. 2321k) and the Arms Export Control Act (22 U.S.C. 2751 et seq.); Presidential Determination No. 2026‑04 (January 14, 2026);
January 23, 2026: 91 Fed. Reg. 3017: Kingdom of Saudi Arabia; Designated a Major Non‑NATO Ally of the United States under section 517 of the Foreign Assistance Act (22 U.S.C. 2321k) and the Arms Export Control Act (22 U.S.C. 2751 et seq.); Presidential Determination No. 2026‑03 (January 13, 2026);
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DDTC Name And Address Changes Posted To Website
January 21 through January 22, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in Name of ThyssenKrupp Marine Systems (Singapore) Pte Ltd to TKMS Singapore Pte Ltd due to corporate rebranding;
- Change in Name of CMI Defence LLC to John Cockerill Defense for Military Industries LLC due to corporate rebranding;
- Change in Address for Enterprise Services Defence and Security UK Ltd., Entserv UK Limited, and ES Field Delivery UK Limited from Royal Pavillion, Wellesley Road, Aldershot, United Kingdom GU11 1PZ to 110 Pinehurst Road, Farnborough Business Park, Farnborough, United Kingdom, GU14 7BF;
- Change in Address for Vicom Australia Pty Ltd., from 1064 Centre Road, Oakleigh South, Victoria 3167, Australia to 1374 North Road, Oakleigh, South, Victoria 3167, Australia;
- Change in Address for Fjord Defense, Inc., from 8 Washington Court, Kennebunkport, Maine to 137 Wildes District Road, Kennebunkport, Maine 04046;
- Change in Name from Helicopter Italy SRL to Airbus Helicopters Italia due to acquisition;
- Change in Name from Telesat LEO Inc. to Telesat LEO ULC due to corporate restructuring;
- Change in Name from Altran Technologies India Private Limited to Capgemini Technology Services India Limited due to acquisition; and
- Change in Name and Address from CAE Aviation Training Inc., 15 Wing Moose Jaw, Moose Jaw, Saskatchewan S6H 7Z8, Canada to CAE Inc., 8585 Chemin de la Cote-de-Liesse, Montreal, Quebec H4T 1G6, Canada due to corporate restructuring.
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DDTC Frequently Asked Questions (FAQs) Related To Registrations With The Department Of State
DECCS IT Support FAQs
Q: What are the file size restrictions for uploading documents in DECCS applications?
A: The file size restrictions for uploading documents in DECCS applications are as follows:
| DECCS Applications | File Size Restriction |
| Advisory Opinions (AO) | 1G |
| Commodity Jurisdiction (CJ) | 1G |
| Speaker Request (SPR) | 20 MB |
| Registration (REG) | 30MB |
| Licensing (LIC) | 30MB |
| Licensing Batch Filed (LICB) | No limit |
If a document exceeds the size limit, the system will reject the upload, and you will need to reduce the file size or split the document into smaller parts before attempting to upload again.
Q: How do I link my user account to my company? I’ve logged in DECCS but don’t see my company information.
A: To link your user account to your company, you must have an active DDTC registration code.
- If you have a DDTC registration code: Request your Corporate Administrator (CA) to link your account by inviting you through Applications → User Management → Add User in DECCS. If your organization does not have an active CA, you can submit a Corporate Administrator Request Letter via a Support Case to become your company’s CA.
- If you do not have a DDTC registration code: Your account will be linked to your company once your registration has been submitted by you and processed by DDTC.
- If you are not planning to register with DDTC: Your information will remain tied to your individual user account rather than being associated with a company.
Q: What is the difference between enrolling in DECCS and registering with DDTC?
A: These are two separate processes often confused by new users:
- Enrolling in DECCS means creating your personal user account in the DECCS portal. This allows you to log in and access applications like Registration, Licensing, or User Management.
- Registering with DDTC is a formal, regulatory process required under ITAR Part 122. It’s how a company submits a Registration application in DECCS to become an approved registrant authorized to conduct ITAR-controlled business.
Q: What browsers does DECCS support?
A: DECCS supports the following web browsers:
- Chrome
- Firefox
- Safari
- Edge (Chromium-based version only)
Note: DECCS does not support Internet Explorer (IE).
Users attempting to access DECCS with unsupported or outdated browsers may encounter error messages on the homepage or application pages. To ensure secure and reliable access to your DECCS data, always use the most up-to-date version of your web browser.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_faq_landing
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notified Congress of Potential FMS Sale To Denmark
January 8, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Denmark of AGM-114R Hellfire Missiles and related equipment for an estimated cost of $45 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Denmark has requested to buy up to one hundred (100) AGM-114R Hellfire Missiles; three (3) AGM-114R Captive Air Test Missiles; six (6) Hellfire (Longbow) M299 Hellfire Launchers; two (2) MHU-191/M trailers; and three (3) BRU-14’s. The following non-MDE items will be included: containers, training aids, weapon software, training, support equipment, spare and repair parts, publications and technical documentation, transportation; U.S. Government and contractor engineering, technical and logistical support services; and other related elements of logistical and program support. The estimated total cost is $45 million.
The principal contractor will be Lockheed Martin Missile and Defense, Ocala, FL. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations.
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DSCA Notified Congress of Potential FMS Sale To Kuwait
January 14, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Kuwait of PATRIOT Program Sustainment and Follow-On Technical Support and related equipment for an estimated cost of $800 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale.
The Government of Kuwait has requested to buy equipment and services related to sustainment and follow-on technical support for its PATRIOT program. The following non-Major Defense Equipment items will be included: spare and repair parts; storage and aging; surveillance firing; stockpile reliability; shared and country-unique PATRIOT PAC-3 Missile Support Center (P3MSC) support; operator and maintenance support; test program set development process support; publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; studies and surveys; transportation; and other related elements of logistics and program support. The estimated total cost is $800 million.
The principal contractors will be RTX Corporation, located in Waltham, MA, and Huntsville, AL; Lockheed Martin, located in Bethesda, MD, and Huntsville, AL; LEIDOS, Inc., located in Reston, VA, and Huntsville, AL; and KBR, located in Houston, TX, 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 Notified Congress of Potential FMS Sale To Iraq
January 14, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Iraq of Very Small Aperture Terminals and related equipment for an estimated cost of $110 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Iraq has requested to buy additional Very Small Aperture Terminals (VSAT); VSAT modems; VSAT hubs; L-band tactical satellite service (L-TAC) manpacks; spare parts; personnel training; U.S. Government and contractor engineering, technical, and logistics support services and personnel services; and other related elements of logistics and program support that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $46 million ($0 in Major Defense Equipment), included VSATs; VSAT modems; VSAT hubs; L-TAC manpacks; commercial satellite services; satellite ground terminals, modems, and hubs; spare parts; field service representative services; and technical support and training. The estimated total cost is $110 million.
The principal contractor will be Network Innovations, located in Frederick, 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 Notified Congress of Potential FMS Sale To Peru
January 15, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Peru of Design and Construction at Callao Naval Base and related elements of logistics and program support for an estimated cost of $1.5 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale.
The Government of Peru has requested to buy equipment and services to support the procurement of maritime and onshore facilities at the Callao Naval Base. The following non-Major Defense Equipment items will be included: lifecycle design; construction; project management; engineering studies; engineering services; technical support; facility and infrastructure assessments; surveys; planning; programming; design; acquisition; contract administration; construction management; 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 $1.5 billion.
Contractor or contractors will be determined later from a list of approved vendors, likely through a competitive process. 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 or contractors.
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DSCA Notified Congress of Potential FMS Sale To Spain
January 29, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Spain of F-100 Frigate Mid-Life Upgrade and related equipment for an estimated cost of $1.7 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Spain has requested to buy five (5) Shipsets AEGIS Weapon System; six (6) Shipsets Digital Signal Processor; five (5) Shipsets MK 41 Baseline VIII Vertical Launching System; five (5) Shipsets of Next Generation Surface Search Radar. The following non-major defense equipment articles (MDE) will also be included: ultra high frequency satellite communications radio terminal systems; Global Positioning System Miniature Precision Lightweight GPS Receiver Engines with M-Code; AN/SRQ-4 Ku-band hardware; material required to support the upgrade of NIXIE SLQ-25A to a SLQ-25E; MK 331 Torpedo Setting Panels; MK 32 surface vessel torpedo tube upgrades; U.S. Government support for the MK 45 Mod 2 and Mod 2B Gun Weapon System; modernization efforts, integration, and test support and equipment; munitions support and support equipment; spare parts; consumables and accessories; repair and return support; classified software delivery and support; classified and unclassified publications; technical documentation; 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. The estimated total cost is $1.7 billion.
The principal contractors will be Lockheed Martin, located in Moorestown, NJ, and Manassas, VA; RTX Corporation, located in Arlington, VA; Ultra Maritime Naval Systems and Sensors, located in Braintree, MA; and General Dynamics, located in Williston, VT. 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 Notified Congress of Potential FMS Sale To Israel
January 30, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Israel of Joint Light Tactical Vehicle and related equipment for an estimated cost of $1.98 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Israel has requested to buy three thousand two hundred fifty (3,250) Joint Light Tactical Vehicles (JLTVs), including JLTV Utility M1279A1/A2/A3 (JLTV-UTL), JLTV Heavy Guns Carrier M1278A1/A2/A3 (JLTV-HGC), JLTV Close Combat Weapons Carrier M1281A1/A2/A3 (JLTV-CCWC), and JLTV General Purpose M1280A1/A2/A3 (JLTV-GP). The following non-MDE items will also be included: Common Remotely Operated Weapon Stations (CROWS); JLTV cargo trailers (M1289); JLTV kits; standard and non-standard command, control, communications, computers, intelligence, surveillance, and reconnaissance equipment; system unique integration; Objective Gunner Protection Kits (OGPK); Driver’s Vision Enhancement (DVE); spare and repair parts; Special Tools and Test Equipment (STTE); technical manuals and publications; maintenance trainers; new equipment training; total package fielding support; depot-level maintenance, repair, and return support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $1.98 billion.
The principal contractor will be AM General LLC, located in Auburn Hills, MI and Mishawaka, IN. 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 Notified Congress of Potential FMS Sale To Israel
January 30, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Israel of AH-64E Apache Helicopters and related equipment for an estimated cost of $3.8 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Israel has requested to buy thirty (30) AH-64E Apache attack helicopters; seventy (70) T700-GE 701D engines (60 installed, 10 spares); thirty (30) AN/ASQ-170 Modernized Target Acquisition and Designation Sight/AN/AAR-11 Modernized Pilot Night Vision Sensors (M-TADS/PNVS); one (1) M-TADS/PNVS in support of Special Repair Activity (SRA); thirty (30) AN/APG-78 Longbow Fire Control Radars (FCR) Mast Mounted Assembly (MMA); one (1) FCR MMA in support of SRA; thirty (30) Longbow Fire Control Radar (FCR) Radar Electronic Units (REU); one (1) Longbow FCR REU in support of SRA; thirty (30) AN/APR-48B Modernized Radar Frequency Interferometers (MRFI); six (6) MRFI maintenance floats; thirty (30) AN/AAR-57 with 5th Sensor Common Missile Warning Systems (CMWS); four (4) AN/AAR-57 with 5th Sensor CMWS maintenance floats; thirty(30) AN/ARC-231A (RT-1987) Very High Frequency/Ultra High Frequency (VHF/UHF) radios; six (6) AN/ARC-231A (RT-1987) Very High Frequency/Ultra High Frequency (VHF/UHF) radios maintenance floats; sixty (60) M36E8 Captive Air Training Missiles (CATM); seventy-two (72) Embedded Global Positioning System/Inertial Navigation Systems with M-code (EAGLE-M) and Multi-Mode Receiver (MMR); thirty-six (36) Common Infrared Countermeasure Systems. The following non-Major Defense Equipment items will also be included: Enhanced Image Intensifier (EI2) cameras; Radar Signal Detecting Sets; Laser Detecting Sets; AN/APX-123A Identification Friend or Foe (IFF) transponders; AN/APR-39 Radar Warning Receiver Signal Detecting Set Improved Data Modems; AN/AVR-2B Laser Warning Set, M299 Missile Launcher, M261 2.75 Inch Rocket Launcher, Small Tactical Terminals; improved countermeasures dispensing systems (ICMD); automatic direction finders; Doppler radar velocity sensors; radar altimeters common core (RACC); tactical air navigation system (TACAN); Global Positioning System receivers; simple key loader; Advanced Weapon System Automatic Machine Guns; rocket launchers; missile launchers; Manned-Unmanned Teaming (MUMT) Unmanned Aerial System (UAS) receiver; MUMT air-air-ground kits; air to ground network radios; transponder test sets; KIV-77 assets; Cartridge Actuated Devices/Propellant Actuated Devices (CAD/PAD); Small Tactical Terminal KOR-24A for Link-16; Longbow Crew Trainer (LCT); tactical engagement simulation (TESS); Maintenance Training Device (MTD); training devices; communication systems; helmets; simulators; generators; aircrew survivability equipment; transportation and organization equipment; spare and repair parts; support equipment; tools and test equipment; technical data and publications; personnel training and training equipment; U.S. Government and contractor technical assistance; technical and logistics support services; and other related elements of program and logistical support. The estimated total cost is $3.8 billion.
The principal contractors will be The Boeing Company, located in Arlington, VA; and Lockheed Martin, located in Orlando, FL. At this time, the U.S. government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Israel
January 30, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Israel of Namer Armored Personnel Carrier Power Packs Less Transmissions and Integrated Logistics Support and related equipment for an estimated cost of $740 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Israel has requested to buy Namer Armored Personnel Carrier (APC-MT883) Power Packs Less Transmissions (NPPLTs) in full and lite configurations. Also included is an integrated logistics support package that includes special tools for C-Level maintenance and transmission parts; control and diagnostic systems; preservation and packaging; containers; configuration management; technical manuals, spare parts catalogs, other documentation, and publications; U.S. Government and contractor technical assistance and contractor non-recurring engineering (NRE); and other related elements of logistics and program support. The estimated total cost is $740 million.
This proposed sale will contribute to the foreign policy and national security of the United States by helping to improve the security of a strategic regional partner that has been, and continues to be, an important force for political stability and economic progress in the Middle East.
The principal contractor will be Rolls-Royce Solutions America, Inc., located in Novi, MI. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notified Congress of Potential FMS Sale To Israel
January 30, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Government of Israel of AW119Kx Light Utility Helicopters and related equipment for an estimated cost of $150 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Government of Israel has requested to buy additional AW-119Kx light utility helicopters; Aviation Ground Support Equipment (AGSE); supplemental type certificate (STC) tools; engineering; spare and repair parts; support equipment; tools and test equipment; technical data and publications; personnel training and training equipment; U.S. Government and contractor technical assistance; technical, and logistics support services; and other related elements of program and logistical support that will be added to a previously implemented case whose value was under the congressional notification threshold. The original Foreign Military Sales case, valued at $78.2 million, included the following non-MDE items: AW-119Kx light utility helicopters, spares, and support. The estimated total cost is $150 million.
The principal contractor will be Leonardo Helicopters USA, AgustaWestland Philadelphia Corporation, located in Philadelphia, PA. 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 Notified Congress of Potential FMS Sale To The Kingdom of Saudi Arabia
January 30, 2026: The State Department has made a determination approving a possible Foreign Military Sale to the Kingdom of Saudi Arabia of PATRIOT Advanced Capability-3 Missile Segment Enhancement Missiles and related equipment for an estimated cost of $9.0 billion. The Defense Security Cooperation Agency delivered the required certification notifying Congress.
The Kingdom of Saudi Arabia has requested to buy seven hundred thirty (730) PATRIOT Advanced Capability-3 Missile Segment Enhancement (PAC-3 MSE) missiles. The following non-major defense equipment items will be included: PAC-3 MSE missile launcher conversion kits; PATRIOT automated logistics systems kits; PAC-3 telemetry kits; PAC-3 MSE shorting plug accumulation kit; PAC-3 MSE missile skid kits; PAC-3 MSE missiles round trainer; PAC-3 MSE empty round trainer; PAC-3 missile and ground support equipment spare parts; PAC-3 missile canister consumables; PAC-3 field surveillance program; integration and test support and equipment; munitions support and support equipment; spare parts, consumables, accessories, and repair and return support; classified software delivery and support; classified and unclassified publications and technical documentation; 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. The estimated total cost is $9.0 billion.
The principal contractor will be Lockheed-Martin Corporation, located in Dallas, TX. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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U.S. Department of Commerce’s Bureau of Industry and Security (BIS)
Revision to License Review Policy for Advanced Computing Commodities
January 15, 2026: 91 Fed. Reg. 1684: The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule effective January 15, 2026, revising its export license review policy for certain advanced computing semiconductors to China and Macau. The rule changes the default standard from a “presumption of denial” to a case‑by‑case review for specified chips, including the NVIDIA H200 and equivalent products, as well as some less advanced chips, if strict certification and testing conditions are met. These conditions require exporters to certify sufficient U.S. domestic supply, ensure exports do not divert global foundry capacity away from U.S. needs, confirm adequate security procedures by the recipient, and submit the items to independent, third‑party performance testing in the United States. BIS states the revision is intended to balance national security and foreign policy objectives with preserving U.S. leadership in artificial intelligence.
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Streamlining Export Controls for Drone Exports
January 21, 2026: 91 Fed. Reg. 2467: The Bureau of Industry and Security (BIS) issued an interim final rule, effective January 20, 2026, to ease U.S. export controls on certain civil unmanned aerial vehicles (UAVs) in order to improve the global competitiveness of U.S. drone manufacturers while maintaining national security safeguards.
The rule eliminates license requirements for exports of low‑risk commercial drones—specifically UAVs with less than one hour of endurance and broad foreign availability—to most Wassenaar Arrangement participating countries (Country Group A:1). This change reflects BIS’s assessment that these drones no longer present significant national security risks.
For more capable but still non‑military drones, such as long‑range cargo delivery and agricultural spraying UAVs, the rule allows exports to close U.S. allies and partners (Country Group A:5) under License Exception Strategic Trade Authorization (STA). Use of STA requires advance notification, reporting, and foreign recipient assurances to ensure appropriate end use and prevent diversion.
BIS emphasized that the rule does not relax controls on military‑grade UAVs, drones designed for combat, intelligence gathering, surveillance, or autonomous strike capabilities, or exports to restricted destinations or end users of concern, which remain subject to strict licensing and due‑diligence requirements.
The changes are made pursuant to Executive Order 14307, “Unleashing American Drone Dominance,” and are intended to reduce regulatory friction for U.S. commercial and public‑safety drone exporters while preserving protections tied to national security and foreign policy. BIS is accepting public comments through February 19, 2026, before deciding whether to finalize or modify the rule.
Check out our article on the change: https://www.linkedin.com/pulse/sky-turning-red-white-blue-fd-associates-inc--lgz4e
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U.S. Census Bureau
2026 Schedule B List Released
https://www.census.gov/foreign-trade/schedules/b/2026/index.html
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
January 7, 2026: Exyte Shanghai Ltd., (“Exyte China”) is a member of the Exyte group located in the People’s Republic of China. As described further below, between on or about March 8, 2021, through on or about March 24, 2022, Exyte China violated the Export Administration Regulations (“EAR”) when it caused, counseled, procured, or aided the in-country transfer of items subject to the EAR to a party on the Entity List without the required license or other authorization from BIS. Specifically, Exyte China caused, counseled, procured, and aided the transfer of approximately 884 EAR99 items used to fabricate semiconductors to Semiconductor Manufacturing International (Beijing) Corporation (“SMIC Beijing”), a party on the Entity List. At all relevant times, a license for the export, reexport, or transfer (in-country) of items subject to the EAR to SMIC Beijing was required under § 744.11 of the Regulations.
BIS and Exyte formalize their agreement, under which Exyte admits the charged conduct and is ordered to pay a $1,500,000 civil penalty within 75 days; failure to pay on time triggers interest, penalty charges, and administrative fees under the Debt Collection Act of 1982, as detailed in the accompanying Notice. Full and timely payment is also made an explicit condition for Exyte’s eligibility for any export license, license exception, permission, or privilege going forward. The Order further requires that the Proposed Charging Letter, Settlement Agreement, and Final Order be made public, and it states that the Order constitutes the final agency action, effective immediately, signed by Assistant Secretary David Peters in January 2026.
https://www.bis.gov/media/documents/exyte-order-final.pdf
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January 12, 2026: The Justice Department announced that Jinchao Wei, a former U.S. Navy sailor who was convicted of espionage by a federal jury in August 2025, was sentenced in federal court to 200 months in prison. Wei, 25, also known as Patrick Wei, was arrested in August 2023 on espionage charges as he arrived for work on the amphibious assault ship U.S.S. Essex at Naval Base San Diego, the homeport of the Pacific Fleet. He was indicted by a federal grand jury, accused of selling national defense information to an intelligence officer working for the People’s Republic of China for $12,000.
Following a five-day trial and one day of deliberation, the jury convicted Wei of six crimes, including conspiracy to commit espionage, espionage, and unlawful export of, and conspiracy to export, technical data related to defense articles in violation of the Arms Export Control Act and the International Traffic in Arms Regulations. He was found not guilty of one count of naturalization fraud.
https://www.justice.gov/opa/pr/former-us-navy-sailor-sentenced-200-months-spying-china
Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
January 6, 2026: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 13P, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024."
Russia-related General License 13P: U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern daylight time, April 9, 2026.
This general license does not authorize:
(1) 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 of the Russian Federation; 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, unless separately authorized.
Effective January 6, 2026, General License No. 13O, dated September 29, 2025, is replaced and superseded in its entirety by this General License No. 13P.
Additionally, OFAC published two amended Russia-related Frequently Asked Questions, FAQ 999 and FAQ 1118.
FAQ 999: What authorizations exist for entities subject to Directive 4 under Executive Order (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," as amended (Russia-related Sovereign Transactions Directive)?
OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.
OFAC issued Russia-related General License (GL) 115C to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.
OFAC issued GL 13P to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons' day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13P, see FAQ 1118.
OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity's sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.
Note that GL 13P, GL 14, GL 115C, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.
FAQ 1118: As of December 2022, the Government of the Russian Federation may require a so-called "exit tax" payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called "exit tax"? Does Russia-related General License (GL) 13P authorize transactions that involve the payment of this exit tax?
Directive 4 under Executive Order (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," as amended (Russia-related Sovereign Transactions Directive), prohibits the following activities by U.S. persons: any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (collectively, "Directive 4 entities"). As noted in FAQ 1002, this includes both direct and indirect transactions.
OFAC issued the Russia-related Sovereign Transactions Directive with the explicit aim of preventing the Government of the Russian Federation from leveraging these institutions and their holdings of international reserves in ways that would undermine the impact of U.S. sanctions. Information currently available to OFAC suggests so-called "exit taxes" imposed by the Government of the Russian Federation involve payments to Directive 4 entities. Consequently, U.S. persons whose divestment from the Russian Federation will involve the payment of such an exit tax require a specific license from OFAC prior to the payment of such tax, unless otherwise authorized by OFAC.
GL 13P authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving Directive 4 entities that would otherwise be prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons' day-to-day operations in the Russian Federation. Payment of exit taxes is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, is not authorized under GL 13P.
Therefore, U.S. persons whose divestment of assets in the Russian Federation will involve a payment of such an "exit tax" should seek a specific license from OFAC. Such persons may submit a request for a specific license with OFAC's Licensing Division online at https://ofac.treasury.gov/ofac-license-application-page. License applications related to these payments should include information regarding the amount of the exit tax, the amount of ongoing taxes that would otherwise be paid to the Government of the Russian Federation should divestment not occur, the impact of a failure to pay the tax on the employees of the exiting company, the specific economic activity in Russia of the exiting company, and the impact on the Russian Federation of the divestment. OFAC will expedite its review of such requests, which will be evaluated on a case-by-case basis.
While OFAC is aware that the Commission established by the Russian Federation to review such divestments may include individuals from entities subject to the Russia-related Sovereign Transactions Directive or individuals listed on the Specially Designated Nationals and Blocked Persons List, U.S. persons do not need to seek authorization from OFAC for their Russian buyers to submit an application to the Commission regarding a divestment transaction.
https://ofac.treasury.gov/recent-actions/20260106 and https://ofac.treasury.gov/media/934881/download?inline and https://ofac.treasury.gov/faqs/999 and https://ofac.treasury.gov/faqs/1118
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January 13, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the Department of State, took action pursuant to the Administration’s policy to curtail the pernicious influence of the Muslim Brotherhood and protect the United States and its partners from Muslim Brotherhood chapters’ support for terrorism. Chapters of the Muslim Brotherhood purport to be legitimate civic organizations while, behind the scenes, they explicitly and enthusiastically support terrorist groups like Hamas. Consequently, OFAC designated the Egyptian and Jordanian branches of the Muslim Brotherhood for their material support to Hamas as Specially Designated Global Terrorists pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended.
The following individual has been added to OFAC's SDN List:
- Taqqosh, Muhammad Fawzi of Lebanon.
The following entities have been added to OFAC's SDN List:
- Egyptian Muslim Brotherhood of Egypt;
- Jordanian Muslim Brotherhood of Jordan; and
- Lebanese Muslim Brotherhood of Lebanon.
https://home.treasury.gov/news/press-releases/sb0357 and https://ofac.treasury.gov/recent-actions/20260113
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January 14, 2026: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 131B, "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 131B: 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, February 28, 2026, 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, February 28, 2026. All blocked accounts of LIG Entities may be used, debited, or credited for the transactions authorized in this paragraph.
This general license does not authorize:
(1) The unblocking of any property blocked pursuant to any part of 31 CFR chapter V;
(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 blocked persons described above, unless separately authorized; or
(3) The transfer of funds to any person or account located in the Russian Federation.
Effective January 14, 2026, General License No. 131A, dated December 10, 2025, is replaced and superseded in its entirety by this General License No. 131B.
Additionally, OFAC is publishing two amended Frequently Asked Questions (FAQs 1224 and 1225).
FAQ 1224: What negotiations does Russia-related General License 131B authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?
On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia's energy sector and degrade Russia's ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131B, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG's majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131B expires on February 28, 2026.
GL 131B does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131B must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC's Russia sanctions is to place pressure on Moscow to end its war.
As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG's ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG's assets to seek OFAC review before further divestment of material LIG assets.
OFAC may revoke GL 131B at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.
FAQ 1225: What activities do Russia-related General License 128B and General License 131B authorize related to Lukoil International GmbH (LIG)?
OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries ("LIG Entities"): GL 128B and GL 131B. The GLs are similar but have different expiration dates and terms as each serves a different purpose.
- To mitigate the effects of Lukoil's OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. This GL expires on April 29, 2026.
- To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. On January 14, 2026, OFAC issued GL 131B to extend the existing authorization until February 28, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128B and GL 131B expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131B. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128B and GL 131B authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.
Both GL 128B and GL 131B also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.
Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131B. Similarly, non-U.S. persons may rely upon GL 128B and GL 131B regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person's activities are consistent with the terms of GL 128B and GL 131B, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
https://ofac.treasury.gov/recent-actions/20260114 and https://ofac.treasury.gov/media/934896/download?inline and https://ofac.treasury.gov/faqs/1224 and https://ofac.treasury.gov/faqs/1225
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January 15, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against the architects of the Iranian regime’s brutal crackdown on peaceful demonstrators. OFAC also against the shadow banking networks that allow Iran’s elite to steal and launder revenue generated by the country’s natural resources.
The following individuals have been added to OFAC's SDN List:
- ABBASPOUR QOMI, Bashir of Iran;
- ARDAKANI, Masoud Mahdavi of Iran;
- BAGHERI, Nematollah of Iran;
- BUALI, Yadollah of Iran;
- GIVARI, Akbar of Iran;
- HASHEMIFAR, Mohammad Reza of Iran;
- KHAMER, Hamid Reza of Iran;
- LARIJANI, Ali of Iran;
- MALEKI, Azizollah of Iran;
- RASHNO, Mehdi of Iran; and
- SHAMANI, Masoud of Iran.
The following entities have been added to OFAC's SDN List:
- Crystal Gas FZE of Iran;
- Desert Pulse Trading FZE of Iran;
- Empire International Trading FZE of Iran;
- Fardis Prison of Iran;
- Golden Mist PTE. LTD., of Iran;
- HMS Trading FZE of Iran;
- Limonium Petrochemicals Trading LLC SOC of Iran;
- Nanshan LTD, of Iran;
- Naviera Shipping And Trading FZ LLC of Iran;
- Nikan Pezhvak Aria Kish Company of Iran;
- Shine Road Trading FZE of Iran;
- Tejarat Hermes Energy Qeshm of Iran; and
- Turkiz Fuel Trading LLC of Iran.
https://home.treasury.gov/news/press-releases/sb0364 and https://ofac.treasury.gov/recent-actions/20260115
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January 16, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 21 individuals and entities and identifying one vessel that have transferred oil products, procured weapons and dual-use equipment, and provided financial services for Iran-backed terrorist organization Ansarallah, commonly known as the Houthis. This action targets financial conduits between the Iranian government and the Houthis, building on previous Treasury actions to constrict the Iranian regime’s use of its oil wealth to fund regional terrorist proxies at the expense of the Iranian population’s welfare. It also targets key front companies, facilitators, and operatives located in Yemen, Oman, and the United Arab Emirates (UAE) that are part of the Houthis’ vast revenue generation and smuggling networks, which enable the group to sustain its capability to conduct destabilizing regional activities and unprovoked attacks on commercial vessels in the Red Sea.
The following individuals have been added to OFAC's SDN List:
- Adriss, Ahmad of Syria;
- Al Muayyad, Adil Mutahhar Abdallah of Yemen;
- Al-Matari, Ebrahim Ahmed Abdullah of Yemen;
- Al-Sharafi, Zayd 'Ali Ahmed of Yemen;
- Asghar, Imran of the United Arab Emirates and Pakistan;
- Baidhani, Waleed Fathi Salam of Yemen and the United Arab Emirates;
- Bseis, Ahmad of Syria;
- Dahan, Ameen Hamid Mohammed of Yemen;
- Ismail, Ahmad of Syria;
- Pshenichnyy, Alexander Yurovich of Russia; and
- Singh, Ranveer of India.
The following entities have been added to OFAC’s SDN List:
- Adeema Oil FZC of the United Arab Emirates;
- Al Sharafi Oil Companies Services of Yemen;
- Albarraq Shipping Co, Trust Company Complex of the Marshall Islands;
- Al-Ridhwan Exchange And Transfer Company of Yemen;
- Alsaa Petroleum And Shipping FZC of the United Arab Emirates;
- Barash Aviation And Cargo Company Limited of Yemen;
- New Ocean Trading FZE of the United Arab Emirates;
- Rabya For Trading FZC of Oman;
- Sama Airline of Yemen; and
- Wadi Kabir Co. For Logistics Services of Oman.
The following vessel has been added to OFAC’s SDN List:
- Albarraq Z Vessel Registration Identification IMO 9252943; MMSI 620800006.
https://home.treasury.gov/news/press-releases/sb0367 and https://ofac.treasury.gov/recent-actions/20260116
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January 21, 2026: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) released a Quarterly Report of Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by OFAC under Section 906(a)(1) of the TSRA from July through September 2025. Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran under the specific licensing regime set forth in Section 906 of the TSRA.
https://ofac.treasury.gov/recent-actions/20260121_33
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January 22, 2026: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated five Costa Rican nationals and five Costa Rica-based entities for their involvement in narcotics trafficking and money laundering. A key global cocaine transshipment point, Costa Rica has become an increasingly significant waypoint for criminal organizations trafficking cocaine to the United States. The network designated is responsible for transporting multi-ton quantities of cocaine from Colombia, storing the drugs in Costa Rica, and ultimately shipping them to the United States and Europe. Luis Manuel Picado Grijalba, the leader of this network, is one of the most prolific drug traffickers operating in the Caribbean.
The following individuals have been added to OFAC's SDN List:
- Mc Donal Rodriguez, Anita Yorleny of Costa Rica;
- Mc Donald Rodriguez, Estefania of Costa Rica;
- Pena Russell, Tonny Alexander of Costa Rica;
- Picado Grijalba, Jordie Kevin of Costa Rica; and
- Picado Grijalba, Luis Manuel of Costa Rica.
The following entities have been added to OFAC's SDN List:
- 3-101-507688 SA of Costa Rica;
- Asociacion De Lideres Limonenses Del Sector Pesquero of Costa Rica;
- Celajes De York Cdy SA of Costa Rica;
- Inversiones Laurita L And L SA of Costa Rica; and
- Magic Esthetic Salon SA of Costa Rica.
https://home.treasury.gov/news/press-releases/sb0369 and https://ofac.treasury.gov/recent-actions/20260122
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January 23, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) increased pressure on Iran’s shadow fleet. OFAC targeted nine shadow fleet vessels and their respective owners or management firms that have collectively transported hundreds of millions of dollars’ worth of Iranian oil and petroleum products to foreign markets. This revenue, which rightfully belongs to the Iranian people, is instead diverted to fund its regional terrorist proxies, weapons programs, and security services, instead of the basic economic services the Iranian people have bravely demanded.
OFAC also issued Iran-related General License T, "Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on January 23, 2026."
Iran-related General License T: All transactions prohibited by Executive Order (E.O.) 13902 that are ordinarily incident and necessary to one or more of the following activities involving the blocked vessels or blocked persons listed in the Annex to this general license, and any entity in which the listed blocked persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time, February 22, 2026, provided that any payment to a blocked person must be made into a blocked interest-bearing account located in the United States:
(1) The safe docking and anchoring in any port, excluding ports located in Iran or the Russian Federation or Venezuela, or under the control of the Government of Iran or the Government of the Russian Federation or the Government of Venezuela, of the blocked vessels listed in the Annex to this general license (the “Blocked Vessels”);
(2) The preservation of the health or safety of the crew of any of the Blocked Vessels;
(3) Emergency repairs of any of the Blocked Vessels or environmental mitigation or protection activities relating to any of the Blocked Vessels; or
(4) The delivery and offloading of cargo involving the Blocked Vessels, provided that the cargo is not of Iranian-origin and was loaded on or before January 23, 2026, and that the delivery and offloading of cargo does not occur at any port located in Iran or the Russian Federation or Venezuela, or under the control of the Government of Iran or the Government of the Russian Federation or the Government of Venezuela.
Note 1: The authorization above includes services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage. This general license does not authorize:
(1) The entry into any new commercial contracts involving the property or interests in property of any blocked persons, including the blocked persons described in paragraph (a) of this general license, except as authorized above; or
(2) Any transactions or activities prohibited by E.O. 13902, except as authorized above, or any transaction or activity prohibited by any other E.O. or any part of 31 CFR chapter V, including any transaction or activity involving Iran, the Government of Iran, or Iranian-origin goods or services that is prohibited by the Iranian Transactions and Sanctions Regulations (31 CFR part 560).
Additionally, OFAC has updated the Specially Designated Nationals and Blocked Persons List.
The following entities have been added to OFAC's SDN List:
- AAYAT Ship Management Private Limited of India;
- Benoil Shipping Inc of Liberia;
- Black Stone Oil And Gas of Oman;
- Galeran Service Corp of the Seychelles;
- Horizon Harvest Shipping LLC of the United Arab Emirates;
- Longevity Shipping Limited of the Marshall Islands;
- Odyssey Marine Inc., of the Marshall Islands; and
- Trade Bridge Global Inc., of the Marshall Islands.
The following vessels have been added to OFAC’s SDN List:
- Al Diab II Vessel Registration Identification IMO 9053816; MMSI 511100397;
- Aqua Spirit Vessel Registration Identification IMO 9197727; MMSI 352001226;
- Avon Vessel Registration Identification IMO 9034705; MMSI 620800259;
- Cesaria Vessel Registration Identification IMO 9251602; MMSI 511101849;
- Chiron 5 Vessel Registration Identification IMO 9306665; MMSI 620827000;
- Eastern Hero Vessel Registration Identification IMO 9353905; MMSI 511101182;
- Keel Vessel Registration Identification IMO 9176929; MMSI 620800174;
- Longevity 7 Vessel Registration Identification IMO 9240885; and
- Sea Bird Vessel Registration Identification IMO 9088536; MMSI 511101458.
https://home.treasury.gov/news/press-releases/sb0370 and https://ofac.treasury.gov/recent-actions/20260123 and https://ofac.treasury.gov/media/934946/download?inline
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January 29, 2026: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 46, "Authorizing Certain Activities Involving Venezuelan-Origin Oil."
Venezuela-related General License 46: All transactions prohibited by the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelanorigin oil, including the refining of such oil, by an established U.S. entity are authorized, provided that:
(1) Any contract for such transactions with the Government of Venezuela, PdVSA, or PdVSA Entities specify that the laws of the United States or any jurisdiction within the United States govern the contract and that any dispute resolution under the contract occur in the United States; and
(2) Any monetary payment to a blocked person is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury.
Note 1: For purposes of this general license, the term “established U.S. entity” means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025.
Note 2: Transactions authorized include arranging shipping and logistics services, including chartering vessels, obtaining marine insurance and protection and indemnity (P&I) coverage, and arranging port and terminal services, including with port authorities or terminal operators that are part of the Government of Venezuela. The above also authorizes commercially reasonable payments in the form of swaps of crude oil, diluents, or refined petroleum products.
This general license does not authorize:
(1) Payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela;
(2) Any transaction involving a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
(3) Any transaction involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
(4) The unblocking of any property blocked pursuant to the VSR; or (5) Any transaction involving a blocked vessel.
Any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil to countries other than the United States pursuant to this general license must provide a detailed report to Sanctions_inbox@state.gov and VZReporting@doe.gov that identifies, for each of these transactions:
(1) The parties involved;
(2) The quantities, values, and countries of ultimate destination;
(3) The dates the transactions occurred; and
(4) Any taxes, fees, or other payments provided to the Government of Venezuela.
Reports described above are due ten days after the execution of the first of such transactions and every 90 days thereafter while such transactions are ongoing.
Note to General License No. 46: Nothing in this general license relieves any person from compliance with the requirements of other Federal agencies, including the Department of Commerce’s Bureau of Industry and Security.
https://ofac.treasury.gov/recent-actions/20260129 and https://ofac.treasury.gov/media/934886/download?inline
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January 30, 2026: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took additional action against Iranian officials responsible for the regime’s brutal crackdown on its own people. Among the officials sanctioned is Eskandar Momeni Kalagari —Iran’s Minister of the Interior—who oversees the murderous Law Enforcement Forces of the Islamic Republic of Iran (LEF), a key entity responsible for the deaths of thousands of peaceful protestors.
OFAC also designated Babak Morteza Zanjani, a criminal Iranian investor who previously embezzled billions of dollars in Iranian oil revenue that rightfully belonged to the Iranian people and was never fully recovered. Freed from imprisonment in order to launder money for the regime, Zanjani has provided financial backing for major projects that support the Islamic Revolutionary Guard Corps (IRGC) and the Iranian regime more broadly.
The following individuals have been added to OFAC's SDN List:
- Damghani, Hamid of Iran;
- Hajian, Mehdi of Iran;
- Kamali, Hossein Zare of Iran;
- Khademi, Majid of Iran;
- Momeni Kalagari, Eskandar of Iran;
- Valizadeh, Ghorban Mohammad of Iran; and
- Zanjani, Babak Morteza of Iran.
The following entities have been added to OFAC's SDN List:
- Zedcex Exchange LTD of the United Kingdom; and
- Zedxion Exchange LTD of the United Kingdom.
https://home.treasury.gov/news/press-releases/sb0375 and https://ofac.treasury.gov/recent-actions/20260130