This newsletter is a listing of the latest changes in export control regulations through September 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
President
Restoring the United States Department of War
September 5, 2025: Section 1. Purpose. On August 7, 1789, 236 years ago, President George Washington signed into law a bill establishing the United States Department of War to oversee the operation and maintenance of military and naval affairs. It was under this name that the Department of War, along with the later formed Department of the Navy, won the War of 1812, World War I, and World War II, inspiring awe and confidence in our Nation’s military, and ensuring freedom and prosperity for all Americans. The Founders chose this name to signal our strength and resolve to the world. The name “Department of War,” more than the current “Department of Defense,” ensures peace through strength, as it demonstrates our ability and willingness to fight and win wars on behalf of our Nation at a moment’s notice, not just to defend. This name sharpens the Department’s focus on our own national interest and our adversaries’ focus on our willingness and availability to wage war to secure what ours is. President Trump has therefore determined that this Department should once again be known as the Department of War and the Secretary should be known as the Secretary of War.
Sec. 2. Implementation. (a) The Secretary of Defense is authorized the use of this additional secondary title — the Secretary of War — and may be recognized by that title in official correspondence, public communications, ceremonial contexts, and non-statutory documents within the executive branch.
(b) The Department of Defense and the Office of the Secretary of Defense may be referred to as the Department of War and the Office of the Secretary of War, respectively, in the contexts described in subsection (a) of this section.
(c) The provisions of this section shall also apply, as appropriate, to subordinate officials within the Department of Defense, who may use corresponding secondary titles such as Deputy Secretary of War or Under Secretary of War in the contexts described in subsection (a) of this section.
(d) All executive departments and agencies shall recognize and accommodate the use of such secondary titles in internal and external communications, provided that the use of such titles does not create confusion with respect to legal, statutory, or international obligations.
(e) Statutory references to the Department of Defense, Secretary of Defense, and subordinate officers and components shall remain controlling until changed subsequently by the law.
(f) Within 30 days of the date of this order, the Secretary of War shall submit to the President, through the Assistant to the President for National Security Affairs, a notification for transmittal to the Congress of any office, executive department or agency, component, or command that begins using a secondary Department of War designation.
(g) Within 60 days of the date of this order, the Secretary of War shall submit to the President, through the Assistant to the President for National Security Affairs, a recommendation on the actions required to permanently change the name of the Department of Defense to the Department of War. This recommendation shall include the proposed legislative and executive actions necessary to accomplish this renaming.
Sec. 3. General Provisions. (a) Nothing in this order shall be construed to impair or otherwise affect:
(i) the authority granted by law to an executive department or agency, or the head thereof; or
(ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
(b) This order shall be implemented consistent with applicable law and subject to the availability of appropriations.
(c) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
(d) The costs for publication of this order shall be borne by the Department of War.
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Department of State, Directorate of Defense Trade Controls (DDTC)
Continuation of Cyprus Defense Trade Policy in the International Traffic in Arms Regulations for Fiscal Year 2026
September 9, 2025: 90. Fed. Reg. 43388: Secretary Rubio determined and certified to Congress that the Republic of Cyprus has met the necessary conditions under the National Defense Authorization Act for Fiscal Year (FY) 2020 (P.L. 116-92) and the Eastern Mediterranean Security and Energy Partnership Act of 2019 (P.L. 116-94, Div. J.) to allow the Department to approve licenses and other approvals for exports, reexports, and transfers of defense articles and defense services to the Republic of Cyprus for FY 2026.
Secretary Rubio’s actions continue the Department’s existing policy, which first suspended the status of the Republic of Cyprus as a proscribed destination under § 126.1 of the International Traffic in Arms Regulations (ITAR) on October 1, 2022.
Therefore, the Department of State published a Federal Register notice amending the ITAR § 126.1(r) to specify that the policy of denial as described in § 126.1(r) shall not apply with respect to exports, reexports, and transfers to the Republic of Cyprus for FY 2026 and that the Republic of Cyprus’ status as a proscribed destination is suspended for FY 2026 with respect to exports, reexports, and transfers of defense articles and defense services. The Federal Register notice will also amend the ITAR to suspend the policy of denial for retransfers and temporary imports destined for or originating in the Republic of Cyprus and brokering activities involving the Republic of Cyprus for FY 2026.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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ITAR: U.S. Munitions List Targeted Revisions - Updated ITAR Reorg Redline As Of Effective Date
September 16, 2025: On September 15, 2025, the Department of State final rule entitled “U.S. Munitions List Targeted Revisions” (90 FR 41778, Aug. 27, 2025) became effective, amending ITAR sections 121.0, 121.1, and 126.9. To assist users of the ITAR, the Department provided the following link to the updated ITAR Reorg redline, including all amendments made by that rulemaking. Those changes are identified in the reorg redline by identifier “Rev.16”.
DDTC provided the redlines as a service to the public, but notes that it is not intended to be a substitute for any official publication of the U.S. Government. We direct your attention to the annual edition of the Code of Federal Regulations and to the e-CFR system for the actual regulatory text.
- 87 FR 16396 – ITAR Reorg I – ITAR Redline
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=100861694780b65027972464336d4326
Refer to our article - What The Latest ITAR Revisions Mean For Small Businesses for more details.
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New USML Update And License Submission Errors
September 17, 2025: The latest version of the U.S. Munitions List (USML) went into effect on September 15, 2025, introducing updated USML Categories and Subcategories. Following these changes, some DECCS users have reported encountering error messages when submitting licenses. These errors are likely due to a mismatch between the USML values in licenses drafted before September 15, 2025, prior to the updated USML taking effect.
What This Means for You
If you have received the error message “USML Category & Sub Category contained outdated version information. Update the USML Category and Sub Category to select from the latest USML version.” upon submission of a license in DECCS, please follow the steps below. Licenses created prior to the USML update need to be adjusted to match the new requirements. Please note, these steps apply to all licenses returning this error message, regardless of the USML categories included in the submission.
Steps to Resolve the Issue:
- Log out and log back into DECCS to refresh your session
- Create a copy of the license that is returning the error
- Carefully review the selected USML categories to ensure they align with the updated version, along with the rest of the form and any attached files
- Resubmit the license
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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DDTC Name And Address Changes Posted To Website
September 5, 2025 through September 5, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Name change of Goodrich Aerospace Canada Ltd. to Goodrich Aerospace Canada Corp. due to corporate restructuring;
- Name and Address Change of Salland Engineering (Europe) B.V., Schrevenweg 12, 8024 HA Zwolle, Netherlands to Salland Engineering B.V., Boerendanserdijk 39, 8024 AE Zwolle, Netherlands due to corporate restructuring;
- Name and Address Change of Honeywell Japan Ltd., 7-1, Kaigan 1-chome, Minato-ku, Tokyo, Japan to Japan Honeywell GK, 16-1 Kaigan 1-chome, Minato-ku, Tokyo, Japan due to corporate restructuring.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To Finland
September 10, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Finland has requested to buy up to four hundred five (405) AIM-120D-3 Advanced Medium Range Air-to-Air Missiles (AMRAAM); and eight (8) AIM-120D-3 guidance sections, with precise positioning provided by either the Selective Availability Anti-Spoofing Module or M-Code. The following non-MDE items will be included: AMRAAM control sections, containers, and support equipment; Common Munitions Built-in Test (BIT)/Reprogramming Equipment (CMBRE); ADU-891 adaptor group test sets; munitions support and support equipment; spare parts, consumables and accessories, and repair and return support; weapons software and support equipment; classified software delivery and support; classified publications and technical documentation; personnel training and training equipment; transportation support; site 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 $1.07 billion. 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.
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DSCA Notifies Congress of Potential FMS Sale To Peru
September 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Peru has requested to buy ten (10) F-16C Block 70 aircraft; two (2) F-16D Block 70 aircraft; fourteen (14) F110-GE-129 engines (12 installed, 2 spares); fourteen (14) Improved Programmable Display Generators (12 installed, 2 spares); twelve (12) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM); fifty-two (52) LAU-129 guided missile launchers (48 installed, 4 spares); twelve (12) M61A1 anti-aircraft guns; fourteen (14) Embedded Global Positioning System Inertial Navigation Systems (12 installed, 2 spares); fourteen (14) AN/APG-83 active electronically scanned array Scalable Agile Beam Radars (12 installed, 2 spares); fourteen (14) Modular Mission Computers 7000AH (or next generation mission computer equivalent) (12 installed, 2 spares); twelve (12) AIM-9X Block II Sidewinder missiles; two (2) AIM-9X Block II Sidewinder tactical guidance units; one (1) AIM-9X Block II Sidewinder Captive Air Training Missile (CATM) guidance unit; two (2) AIM-9X Block II Sidewinder CATMs; and fourteen (14) Multifunctional Information Distribution System-Joint Tactical Radio Systems (12 installed, 2 spares). The following non-MDE items will also be included: Infrared Search and Track systems; missile warning systems; AN/ALQ-254 Viper Shield or equivalent electronic warfare systems; AN/AAQ-28 Litening targeting pods; Cartridge Actuated Devices/Propellant Actuated Devices (CAD/PAD); AIM-120C-8 AMRAAM CATMs; Joint Helmet Mounted Cueing Systems II (JHMCS II) helmet-mounted displays; ammunition; cartridges, chaffs, and flares; weapons support equipment; embedded communications security devices; AN/ALE-47 airborne countermeasures dispenser systems; countermeasure processors, sequencer switching units, and Control Display Units; AN/APX-127 advanced identification friend or foe or equivalent; AN/ARC-238 radios; KIV-78A and KY-58M cryptographic devices; AN/PYQ-10 Simple Key Loaders; night vision devices (NVD) and NVD intensifier tubes; ADU-890 and ADU-891 adaptor group computer test sets; Joint Mission Planning System; pylons, launcher adapters, weapon interfaces, and bomb and ejection racks; fuel tanks; Precision Measurement Equipment Laboratory (PMEL) and calibration support; Common Munitions Built-in-Test Reprogramming Equipment; targeting systems; spare and repair parts, consumables, and accessories; repair and return support; aircraft, engine, ground, and pilot life support equipment; classified and unclassified computer program identification number systems; classified and unclassified software and software support; classified and unclassified publications, manuals, and technical documentation; National Geospatial-Intelligence Agency (NGA) maps and mapping data; personnel training and training equipment, simulators, and training devices; studies and surveys; facilities and construction support transportation, ferry, and fuel 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 $3.42 billion.
https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article-Display/Article/4304541/peru-f-16-aircraft
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DSCA Notifies Congress of Potential FMS Sale To Norway
September 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Norway has requested to buy eight hundred sixteen (816) GBU-39/B Small Diameter Bombs Increment I. The following non-MDE items will also be included: spare parts, consumables and accessories, and repair and return support; training aids, devices, and spare parts; classified and unclassified software delivery and support; classified and unclassified publications and technical data; U.S. Government and contractor engineering, logistics, and technical support services; and other related elements of logistics and program support. The estimated total cost is $113 million. The principal contractor will be The Boeing Company, located in Arlington, VA. The purchaser typically requests offsets. 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 Belgium
September 15, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Belgium has requested to buy up to the following quantities: three hundred twenty (320) AIM-9X Block II Sidewinder tactical missiles; two hundred fifty-eight (258) AIM-9X Block II+ Sidewinder tactical missiles; fifty (50) AIM-9X Block II tactical guidance units; and thirty (30) AIM-9X Block II+ tactical guidance units. The following non-Major Defense Equipment items will also be included: missile containers; weapon software; transportation; U.S. Government and contractor engineering, technical, and logistical support services; and other related elements of logistics and program support. The estimated total cost is $567.8 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 the Netherlands
September 16, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of the Netherlands has requested to buy up to two hundred thirty-two (232) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM) and up to eight (8) AIM-120C-8 AMRAAM guidance sections. The following non-Major Defense Equipment items will be included: AMRAAM control section spares, Captive Air Training Missiles, and missile containers; spare parts, consumables and accessories, and repair and return support; weapon system support and software; classified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; transportation support; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $570 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 Norway
September 17, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Norway has requested to buy up to fifty (50) MK 54 MOD 0 lightweight torpedo all up rounds. The following non-MDE items will also be included: torpedo components; containers; 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 logistics and program support. The estimated total cost is $162.1 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 Poland
September 18, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy two thousand five hundred six (2,506) FGM-148F Javelin missiles and two hundred fifty-three (253) Javelin Lightweight Command Launch Units. The following non-MDE items will be included: missile simulation rounds; battery coolant units; tool kits; spares support; training; U.S. Government and contractor technical assistance; transportation; and other related elements of logistics and program support. The estimated total cost is $780 million. The principal contractors will be RTX Corporation, located in Arlington, VA; and Lockheed Martin, located in Tucson, AZ. 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
September 25, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Germany has requested to buy up to four hundred (400) AIM-120D-3 Advanced Medium Range Air-to-Air Missiles (AMRAAM); up to twelve (12) AIM-120D-3 AMRAAM guidance sections, including precise positioning provided by either Selective Availability Anti-Spoofing Module or M-Code; and one (1) AIM-120 AMRAAM Integrated Test Vehicle. The following non-Major Defense Equipment items will also be included: AMRAAM telemetry kits, control sections, containers, and support equipment; ADU-891 Adaptor Group Test sets; KGV-135A encryption devices; spare parts, consumables and accessories, and repair and return support; weapons system support and software; classified and unclassified software delivery and support; classified and unclassified 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 $1.23 billion. 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 by in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Australia
September 30, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of has requested to buy forty-eight (48) M142 High Mobility Artillery Rocket Systems (HIMARS). The following non-MDE items will also be included: M1084A2 HIMARS resupply vehicles; M1095 trailers; Low Cost Reduced Range Practice Rocket (LCRRPR) pods; intercom systems; radio and communication mounts; spare parts and services; U.S. Government and contractor engineering, technical, and logistics support services; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $705 million. The principal contractors will be Lockheed Martin, located in Grand Prairie, TX; L3Harris Corporation, located in Melbourne, FL; Leonardo DRS, located in Arlington, VA; and Oshkosh Corporation, located in Stafford, 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)
Revocation of Validated End-User Authorizations in the People's Republic of China
September 2, 2025: 90. Fed. Reg. 42321: In this final rule, the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) to revise the existing Validated End-User (VEU) Authorizations list for the People's Republic of China (PRC) by removing Intel Semiconductor (Dalian) Ltd; Samsung China Semiconductor Co. Ltd; and SK hynix Semiconductor (China) Ltd.
Validated End-Users (VEUs) are designated entities located in eligible destinations to which eligible items subject to the Export Administration Regulations (EAR) may be exported, reexported, or transferred (in-country) under a general EAR authorization instead of a license (see 15 CFR 748.15 (Authorization Validated End-User (VEU)). The names of the VEUs, as well as the dates they were designated, and the associated eligible destinations (i.e., facilities) and items are identified in supplement no. 7 to part 748 of the EAR. Pursuant to § 748.15, VEU-eligible destinations may obtain eligible items without the need for the VEU's supplier to obtain an export, reexport, or transfer (in-country) license from the Bureau of Industry and Security (BIS). VEU-eligible items vary among VEUs and may include commodities, software, and/or technology, apart from items controlled for missile technology or crime control reasons on the Commerce Control List (CCL) (supplement no. 1 to part 774 of the EAR).
VEUs are reviewed and approved by the U.S. Government in accordance with the provisions of § 748.15 and supplement nos. 8 and 9 to part 748 of the EAR. The End-User Review Committee (ERC) is responsible for administering the VEU program. The ERC is composed of representatives from the Departments of State, Defense, Energy, Commerce, and other agencies, as appropriate. BIS amended the EAR in a final rule published on June 19, 2007 (72 FR 33646) to create Authorization VEU.
Pursuant to § 748.15 and supplement no. 9 to part 748 of the EAR, the ERC determined to remove Intel Semiconductor (Dalian) Ltd, Samsung China Semiconductor Co. Ltd, and SK hynix Semiconductor (China) Ltd from the Validated End User Program.
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Relaxing Export Controls for Syria
September 2, 2025: 90. Fed. Reg 42315: In this final rule, the Bureau of Industry and Security (BIS) made changes to the Syria export control measures under the Export Administration Regulations (EAR), consistent with Executive Order (E.O.) 14312, Providing for the Revocation of Syria Sanctions, which directed the removal of sanctions on Syria. This final rule relaxes the EAR's existing restrictions on exports and reexports to Syria of items subject to the EAR by making the following changes: revising certain restrictive license application review policies that had applied to most items subject to the EAR to be more favorable; expanding existing license exceptions to apply to Syria; and adding new license exceptions for Syria, including for EAR99 items.
In this final rule, BIS makes changes to the export control measures for Syria under the EAR. The three sets of changes being made are described in section II as follows:
- Addition of new or expanded license exception eligibility for exports and reexports to Syria;
- Adoption of more permissive license review policies for exports and reexports to Syria; and
- Other conforming and streamlining updates, including removal of provisions that are obsolete, e.g., General Order No. 2.
https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria
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Statement of Licensing Policy for Export, Reexport, and Transfer (In-Country) Applications Related to Belavia – Belarusian Airlines
September 12, 2025: This Statement of Licensing Policy (SLP) is issued in conjunction with a new letter authorization pertaining to Belavia-Belarusian Airlines (Belavia).
On September 12, 2025, BIS issued a letter authorizing, among other activities, flights of certain Belavia aircraft between Belarus and most other destinations. This letter also authorizes the service, maintenance, repair, overhaul, or refurbishing of such aircraft.
Consistent with this letter, BIS has removed eight Belavia aircraft from its General Prohibition 10 (GP10) list, whose continued listing would otherwise prevent the maintenance, repair, overhaul, or refurbishing of such aircraft.
For exports, reexports, or transfers (in-country) of equipment, supplies, and materials that remain subject to an export license to or for use in connection with Belavia aircraft, license applications now will generally be reviewed on a case-by-case basis to determine whether the items are for the maintenance and use of Belavia’s commercial passenger fleet, and to guard against the risk of diversion to other unsupported end-uses or end-users.
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Department of Commerce Rescinds Firearms Rule, Restoring Common Sense to Export Controls on Civilian Firearms
September 29, 2025: 90. Fed. Reg. 47170: The Department of Commerce’s Bureau of Industry and Security (BIS) rescinded an interim final rule (Firearms IFR), which imposed onerous export controls on civilian firearms and related ammunition and components. The rescission of the Firearms IFR will allow U.S. firearms manufacturers to compete in overseas markets, creating hundreds of millions of dollars per year in export opportunities.
The now-defunct Firearms IFR imposed a range of excessive and burdensome requirements, including:
- A “presumption of denial” for civilian firearms exports to 36 supposedly “high-risk” countries – effectively ceding overseas markets to foreign firearms manufacturers, with no benefit to national security.
• Export license requirements on sporting shotguns and optics to U.S. allies – despite no evidence of any national security risk.
• Bureaucratic hurdles on firearms export licenses, such as extensive documentation requirements and short validity periods.
This rule revokes these requirements and restores the export rules for civilian firearms that existed prior to the IFR. Under these rules, exports of most pistols, rifles, and non-long-barrel shotguns will remain subject to a worldwide export license requirement. Long-barrel shotguns and most optics can be exported without a license to U.S. allies and certain partners. License application paperwork requirements for firearms will be streamlined and consistent with normal BIS practice. BIS and interagency partners will continue to screen firearms license applications to reduce the risk of weapons ending up in the hands of wrongdoers.
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U.S. Census Bureau
NEW BIS LICENSE TYPE C78 – (SPP) Syria Peace and Prosperity
September 2, 2025:
On Tuesday, September 2, 2025 the Department of Commerce, Bureau of Industry and Security (BIS) published a final rule (https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria) with an effective date of September 2, 2025 for most provisions. In this final rule, the Bureau of Industry and Security (BIS) made changes to the Syria export control measures under the Export Administration Regulations (EAR), consistent with Executive Order (E.O.) 14312. This final rule expanded the eligibility of EAR license exceptions for Syria by adding a new license exception for Syria called License Exception Syria Peace and Prosperity (SPP), amending the scope of existing License Exception Consumer Communications Devices (CCD) to add Syria to the country scope, and making additional paragraphs of existing license exceptions available for exports and reexports to Syria.
In § 740.5, currently reserved, this final rule amends the section to add License Exception SPP. New License Exception SPP will authorize exports and reexports to Syria of all items designated EAR99 subject to the terms and conditions therein and the general restrictions set forth under § 740.2 of the EAR. In § 740.5(a) (Scope) of License Exception SPP, this final rule specifies that this license exception will overcome license requirements for the export or reexport of all items designated “EAR99.” Items designated “EAR99” are items subject to the EAR but not specifically described on the Commerce Control List (CCL) in an ECCN.
In § 740.5(b) (Restrictions), this final rule adds this paragraph to specify that License Exception SPP does not authorize exports or reexports prohibited under a part 744 end-use or end-user control, including under § 744.8 for transactions involving persons designated by Office of Foreign Assets Control (OFAC) to the Specially Designated Nationals (SDN) List with certain identifiers.
This final rule as a conforming change adds a reference to License Exception SPP in § 746.9(b)(1) to specify that it is an available license exception for Syria, provided that the export or reexport is not otherwise restricted under § 740.2 and meets all the terms and conditions of License Exception SPP.
New License Code C78 Syria Peace and Prosperity (SPP)
An update has been made to AES to create new License Codes C78 “Syria Peace and Prosperity” (SPP) which authorizes certain export, reexport, and transfer (in-country) of items specified in ECCN EAR99. SPP will authorize exports and reexports to Syria of all items designated EAR99 subject to the terms and conditions therein and the general restrictions set forth under § 740.2 of the EAR. In § 740.5(a) (Scope) of License Exception SPP, this final rule specifies that this license exception will overcome license requirements for the export or reexport of all items designated “EAR99.” Items designated “EAR99” are items subject to the EAR but not specifically described on the CCL in an ECCN.
The full terms of License Exception SPP are described in § 740.5.
AES filers must adhere to the following new reporting when using C78 (SPP) to prevent the return of fatal errors from AES:
- Report License Code: C78 Syria Peace and Prosperity
- Allowable ECCNs: EAR99
- Allowable countries: Syria
- Allowable Export Information Codes: All except UG, FS, FI
- Allowable Modes of Transportation: All except ‘70’ (Fixed Transport)
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UPDATED BIS LICENSE TYPE C58 – (CCD) Consumer Communication Devices
September 2, 2025:
On Tuesday, September 2, 2025 the Department of Commerce, Bureau of Industry and Security (BIS) published a final rule (https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria) with an effective date of September 2, 2025 for most provisions. Among other actions, this final rule expands the eligibility of EAR license exceptions for Syria by amending the scope of existing License Exception Consumer Communications Devices (CCD) to add Syria to the country scope.
In § 740.19 Consumer Communications Devices (CCD), this final rule revises this section to add Syria as an eligible destination under the terms of § 740.19(a). In §740.19(b) (Eligible commodities and software), this final rule revises this paragraph to indicate that all commodities and software described in § 740.19(b) are eligible for export or reexport to Syria pursuant to the terms of § 740.19.
In § 740.19(c)(1) (Organizations), which establishes eligible and ineligible organizations for transactions pursuant to the terms of CCD, this final rule modifies this paragraph to indicate that CCD does not restrict eligibility to any end user in Syria. However, CCD cannot authorize transactions that require a license under part 744 of the EAR or with persons that are sanctioned under programs administered by another agency, including the Departments of State and the Treasury. For example, License Exception CCD may not be used to export consumer communications devices to members of the former regime of Bashar al-Assad, as identified by the Secretary of State or the Secretary of Treasury.
This final rule as a conforming change adds a reference to License Exception CCD in § 746.9(b)(8) to specify that it is an available license exception for Syria, provided that the transaction is not otherwise restricted under § 740.2 and meets all the applicable terms and conditions of License Exception CCD.
Updated License Code C58 (CCD)
An update has been made to AES to License Type Code C58 “Consumer Communication Devices” (CCD), which allows the export and re-export of consumer products related to the free flow of information to, from and among the Cuban, Russian, and the Belarusian, and Syrian people, enabling communications among people within those countries and with the outside world. The rule revises the License Code to indicate that all commodities and software described in § 740.19(b) are eligible for export or reexport to Syria pursuant to the terms of § 740.19. See 740.19 of the EAR. EAR99 may be reported as an ECCN.
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UPDATED BIS LICENSE TYPE C46 – (AVS) Aircraft and Vessels
September 2, 2025:
On Tuesday, September 2, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) published a final rule (https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria) with an effective date of September 2, 2025, for most provisions. Among other actions, this final rule expands the eligibility of EAR license exceptions for Syria by making additional paragraphs of existing license exceptions available for exports and reexports to Syria.
In § 740.15 (License Exception AVS, for Aircraft, vessels and spacecraft) under paragraph (b)(4), this final rule revises this paragraph to ensure that only items designated as EAR99 or controlled on the CCL only for anti-terrorism reasons are eligible to be sent to Syria under paragraph (b) of License Exception AVS. This revised text is intended to ensure that no equipment and spare parts for a vessel or aircraft that could make a significant contribution to the military potential of Syria, including its military logistics capability, or could enhance Syria’s ability to support acts of international terrorism, is authorized to Syria without the required notification to Congress, consistent with 50 USC 4813(c)(2).
This final rule also adds a Note to paragraph (b)(4) to specify that for purposes of paragraph (b)(4), ECCNs 2B999, 3A991, 4A994, 5A992 (except for .z), and 9A991 are treated as ECCNs controlled exclusively for AT reasons.
This final rule as a conforming change adds a reference to License Exception AVS in § 746.9(b)(4) to specify that it is an available license exception for Syria, provided that the transaction is not otherwise restricted under § 740.2 and meets all the applicable terms and conditions of License Exception AVS.
Updated License Code C46 (AVS)
An update has been made to AES to License Type Code C46 “Aircraft and Vessels” (AVS), which allows departure from the United States of foreign registry civil aircraft on temporary sojourn in the United States and of U.S. civil aircraft for temporary sojourn abroad; the export of equipment and spare parts for permanent use on a vessel or aircraft; exports to vessels or planes of U.S., Australian, Canadian, or UK (the United Kingdom) registry and U.S., Australian, Canadian, or UK Airlines' installations or agents; the export or reexport of cargo that will transit Cuba on an aircraft or vessel on temporary sojourn; and the export of spacecraft and components for fundamental research.
This rule broadens the eligibility for Syria by expanding License Exception AVS eligibility to exports of U.S.-registered civil aircraft and vessels and temporary reexports of U.S. and foreign registered civil aircraft and vessels to Syria on temporary sojourn pursuant to the terms of § 740.15(a) - (d) of the EAR. This License Exception is available subject to the restriction that the transaction will not support the Syrian police, military, or intelligence end users pursuant to supplement no. 2 to part 742.
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How to Resolve Common AES Response Messages
September 16, 2025:
When submitting your Electronic Export Information (EEI) to the Automated Export System (AES), you can receive different response messages: Fatal, Compliance, Verify, Informational and Warning. It is important that AES filers address and/or correct Response Messages as soon as they are received to comply with the Foreign Trade Regulations.
To help you take the appropriate action, here is guidance on how to address one of the most frequent Response Messages that were generated in the AES for the previous month.
Response Code: 120
Narrative: Carrier Unknown
Severity: Fatal
Reason: The Carrier ID (SCAC/IATA) reported is not known in AES.
Resolution: For vessel, rail or truck shipments the carrier must be identified with an active SCAC code issued by the National Motor Freight Traffic Association (NMFTA). For air shipments, the carrier must be identified with an active IATA code issued by the International Air Transport Association.
If the Carrier ID (SCAC/IATA) as known at the time of filing is not valid in AES and a valid Carrier ID (SCAC/IATA) cannot be obtained from the carrier, as a last resort, report the Carrier ID as UNKN for vessel, rail or truck shipments. For an unknown air carrier, report one of the acceptable “unknown” codes as follows:
*F or 99F for Unknown Foreign Air Carrier
*U or 99U for Unknown U.S. Air Carrier
*C or 99C for Unknown Canadian Air Carrier
** or 99O for flyway aircraft reported under Chapter 88.
Verify the Mode of Transportation Code and the Carrier ID (SCAC/IATA), 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
Department of Commerce, Bureau of Industry and Security (BIS)
September 9, 2025: Gregory Muñoz (47, Minneola) was sentenced to 18 months in federal prison for conspiracy to commit wire fraud. As part of his sentence, the court also entered an order of forfeiture in the amount of $100,000, the proceeds of the wire fraud. Muñoz pleaded guilty on May 9, 2024.
Muñoz’s co-conspirator, Pen Yu, pleaded guilty in May 2024 and was sentenced to three years and seven months in prison, later reduced to two years and six months in prison. Another co-conspirator, Jonathan Thyng, pleaded guilty in July 2024 and was sentenced to probation.
According to court documents, beginning in at least July 2016 and continuing through at least May 2023, Yu ordered biochemical products from MilliporeSigma, a subsidiary of multinational science and technology company Merck KGaA, Darmstadt, Germany, with help from Muñoz, a MilliporeSigma salesperson, by falsely representing that Yu was affiliated with a biology research lab at a Florida university. This fictitious affiliation led MilliporeSigma to provide Yu millions of dollars’ worth of discounts and other benefits, such as free overnight shipping, not available to the public. Yu gave Muñoz thousands of dollars in gift cards for facilitating these fraudulent discounted orders. When the products arrived at the university stockroom, a stockroom employee diverted the products to Yu, who repackaged them and shipped them to China. To avoid scrutiny, Yu made false statements about the value and contents of these shipments in export documents.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
September 3, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that Fracht FWO Inc. (Fracht), a freight forwarder whose principal place of business is in Houston, Texas, has agreed to pay $1,610,775 to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs, including those on Venezuela and Iran. Fracht contracted with a blocked Government of Venezuela airline to transport goods to Argentina from Mexico on behalf of its customer. The blocked Venezuelan airline used an aircraft blocked by OFAC for being operated by Iran's Mahan Air, which is sanctioned under U.S. terrorism and proliferation authorities. OFAC found Fracht's conduct was egregious and not voluntarily self-disclosed.
https://ofac.treasury.gov/media/934601/download?inline and
https://ofac.treasury.gov/media/934596/download?inline
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September 22, 2025: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that ShapeShift AG, a digital asset exchange incorporated in Switzerland and operating from Denver, Colorado, agreed to pay $750,000 to settle its potential civil liability for apparent violations of multiple sanctions programs. Specifically, ShapeShift engaged in digital asset transactions on its exchange platform with users located in Cuba, Iran, Sudan, and Syria on 17,183 occasions. The settlement amount reflects OFAC's determination that ShapeShift AG's conduct was non-egregious and not voluntarily self-disclosed.
https://ofac.treasury.gov/media/934641/download?inline
https://ofac.treasury.gov/recent-actions/20250922_33
Sanctions
Department of Commerce, Bureau of Industry and Security (BIS)
Additions and Revisions to the Entity List
September 16, 2025: 90 Fed. Reg. 44496: In this rule, the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) by adding 32 entities to the Entity List. These entries are listed on the Entity List under the destination of China, People's Republic of (China) (23), India, (1), Iran (1), Singapore (1), Taiwan (1), Turkey (3), and the United Arab Emirates (UAE) (2). These entities have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States. This final rule revises an entry by removing two addresses from one entity under the destination of Russia. Finally, this rule amends 27 existing entries on the Entity List to correct typographical errors under the following destinations: Belarus (3), China (11), Iran (1), Pakistan (1), Russia (9), and Turkey (2), and the United Arab Emirates UAE (2).
The entities to be added:
China
- Aerospace Information Research Institute, Chinese Academy of Sciences,
- Beijing Fudan Microelectronics Technology Co., Ltd.,
- Beijing Tianyi Huiyuan Biotechnology Co., Ltd.,
- Beijing Tsingke Biotech Co., Ltd.,
- Changsha NetForward Electronic Technology Co. Ltd.,
- Changzhou Netforward Microelectronics Co., Ltd.,
- Chengdu NetForward Microelectronics Co., Ltd.,
- Chinese Academy of Sciences, National Time Service Center,
- GMC Semiconductor Technology (Wuxi) Co., Ltd.,
- Hong Kong DEMX Co., Ltd.,
- Hua Ke Logistics (HK) Limited,
- Hua Ke Supply Chain (HK) Limited,
- Jicun Semiconductor Technology (Shanghai) Co., Ltd.,
- Sangon Biotech (Shanghai) Co., Ltd.,
- Shanghai Fudan Microelectronics Co., Ltd.,
- Shanghai Fudan Microelectronics (HK) Co., Ltd.,
- Shanghai Fukong Hualong Microsystem Technology Co., Ltd.,
- Shanghai Fuwei Xunjie Digital Technology Co., Ltd.,
- Shanghai Suochen Information Technology Co., Ltd.,
- Shenzhen Fudan Microelectronics Co., Ltd.,
- Shenzhen NetForward Microelectronics Co., Ltd.,
- Shenzhen Xinlikang Supply Chain Management Co., Limited, and
- Sino IC Technology Co., Ltd.
India
- AR Sales Pvt Ltd.
Iran
- Smart Mail Services.
Singapore
- Shanghai Fudan Microelectronics (HK) Co., Ltd.
Taiwan
- Shanghai Fudan Microelectronics (HK) Co., Ltd.
Turkey
- Atempo Proje Taahhüt Ses ve Görüntü Sistemleri Anonim Şirketi İstanbul Şubesi,
- Dentun Elektronik, and
- EB Teknoloji Sistemleri Anonim Şirketi.
United Arab Emirates
- HAS General Trading LLC, and
- Smart Mail Services.
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Department of Commerce Expands Entity List to Cover Affiliates of Listed Entities
September 29, 2025: 90 Fed. Reg. 47201: The Department of Commerce’s Bureau of Industry and Security (BIS) issued a new rule that closes a significant loophole in restricted party lists – strengthening the export control regime overall.
Under this rule, any entity that is at least 50 percent owned by one or more entities on the Entity List or the Military End-User (MEU) List will itself automatically be subject to Entity List/MEU List restrictions. In addition, significant minority ownership by an Entity List/MEU List company is a red flag that triggers additional due diligence requirements for exporters. Previously, the Entity List and MEU List completely excluded all entities that were not specifically named on the Entity List/MEU List – even if there were extensive corporate and financial ties with listed entities.
BIS’ Entity List and MEU List impose stringent supplemental export license requirements on parties involved in activities contrary to U.S. national security or foreign policy interests, or whether there is an unacceptable risk of use in or diversion to a military end use. While the license review policy for parties on the Entity List or MEU List is generally a presumption of denial, exporters can always apply for a license.
The public is invited to comment on this rule within 30 days of publication in the Federal Register. The restrictions in the rule will be immediately effective, with some exceptions available up to 60 days after publication in the Federal Register.
See our article - From FOCI to the 50% Rule – BIS/EAR New Ownership Test for more details
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
September 2, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of shipping companies and vessels led by Iraqi-Kittitian businessman Waleed al-Samarra’i (al-Samarra’i) for smuggling Iranian oil disguised as Iraqi oil. This network operates primarily by covertly blending Iranian oil with Iraqi oil, which is then marketed intentionally as solely of Iraqi origin to avoid sanctions. This scheme has generated hundreds of millions of dollars in revenue for both the Iranian regime and al-Samarra’i himself.
The following individual has been added to OFAC’s SDN List:
- Al-Samarra’I, Waleed Khaled Hameed of the United Arab Emirates.
The following entities have been added to OFAC’s SDN List:
- Babylon Navigation DMCC of the United Arab Emirates;
- Galaxy Oil FZ LLC of the United Arab Emirates;
- Keely Shiptrade Limited of the Marshall Islands;
- Oidar Management S.A. of the Marshall Islands;
- Panarea Marine S.A. of the Marshall Islands;
- Topsail Shipholding Inc. of the Marshal Islands; and
- Tryfo Navigation Inc. of the Marshall Islands.
The following vessels have been added to OFAC’s SDN List:
- Adena (D5ZY7) Crude Oil Tanker Liberia flag; MMSI 636020606 (vessel);
- Alexandra (5LLV6) Crude Oil Tanker Liberia flag; MMSI 636023078 (vessel);
- Bellagio (9V6969) Chemical/Products Tanker Liberia flag; MMSI 636024318 (vessel);
- Bianca (5LOX8) Chemical/Products Tanker Liberia flag; MMSI 636023688 (vessel);
- Camilla (5LAB7) Crude Oil Tanker Liberia flag; MMSI 636020658 (vessel);
- Delfina (5LJW7) Crude Oil Tanker Liberia flag; MMSI 636022667 (vessel);
- Liliana (AUHB) Crude Oil Tanker Liberia flag; MMSI 636024578 (vessel);
- Paola (5LTG7) Chemical/Products Tanker Liberia flag; MMSI 636024577 (vessel); and
- Roberta (5LOG7) Oil Products Tanker Liberia flag; MMSI 636023554 (vessel).
https://ofac.treasury.gov/recent-actions/20250902
https://ofac.treasury.gov/recent-actions/20250902
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September 3, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Guangzhou Tengyue Chemical Co., Ltd. (Guangzhou Tengyue), a chemical company operating in China that is involved in the manufacture and sale of synthetic opioids to Americans. In addition to opioids, Guangzhou Tengyue has also sold dangerous analgesic chemicals often used as cutting agents that are mixed with synthetic opioids and other illicit drugs. Also, OFAC sanctioned Huang Xiaojun and Huang Zhanpeng, representatives of Guangzhou Tengyue, who were directly involved in coordinating the shipments of these illicit drugs and cutting agents to the United States.
The following individuals have been added to OFAC’s SDN List:
- Huang, Xiaojun of China; and
- Huang, Zhanpeng of China.
The following entity has been added to OFAC’s SDN List:
- Guangzhou Tengyue Chemical Co., Ltd of China.
https://ofac.treasury.gov/recent-actions/20250903
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September 4, 2025: The State Department designated Three foreign NGOs—Al Haq, Al Mezan Center for Human Rights (Al Mezan), and the Palestinian Centre for Human Rights (PCHR)—pursuant to Executive Order 14203, “Imposing Sanctions on the International Criminal Court.” These entities have directly engaged in efforts by the International Criminal Court (ICC) to investigate, arrest, detain, or prosecute Israeli nationals, without Israel’s consent.
The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued International Criminal Court-related General License 10, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 4, 2025.
GENERAL LICENSE NO. 10 “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 4, 2025”
(a) All transactions prohibited by the International Criminal Court-Related Sanctions Regulations (ICCSR), 31 CFR part 528, that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern daylight time, October 4, 2025, provided that any payment to a blocked person is made into a blocked interestbearing account located in the United States, in accordance with the ICCSR:
(1) Al Haq Law in the Service of Mankind;
(2) Al Mezan Center for Human Rights;
(3) Palestinian Centre for Human Rights; or
(4) 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.
The following entities have been added to OFAC’s SDN List:
- Al Haq – Law in the Service of Mankind of Palestine;
- Al Mezan Center for Human Rights of Palestine; and
- Palestinian Centre for Human Rights of Palestine.
https://ofac.treasury.gov/media/934606/download?inline
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September 8, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented sanctions against a large network of scam centers across Southeast Asia that steal billions of dollars from Americans using forced labor and violence. The action includes nine targets operating in Shwe Kokko, Burma, a notorious hub for virtual currency investment scams under the protection of the OFAC-designated Karen National Army (KNA), as well as ten targets based in Cambodia.
The following individuals have been added to OFAC’s SDN List:
- Chen, Al Len of China;
- Dong, Lecheng of Cambodia;
- OO, Saw Min Min of Burma;
- She, Zhijiang of China;
- Su, Liangsheng of China;
- Win, Tin of Burma; and
- Xu, Aimin of China.
The following entities have been added to OFAC’s SDN List;
- Chit Linn Myaing Mining and Industry Company Limited of Burma;
- Chit Linn Myaing Toyota Company Limited of Burma;
- Chit Linn Mying Co., Ltd. of Burma;
- Heng He Bavet Propert Co Ltd of Cambodia;
- HH Bank Cambodia PLC of Cambodia;
- K B Hotel Co Ltd of Cambodia;
- K B X Investment Co Ltd of Cambodia;
- M D S Heng He Investment Co Ltd of Cambodia;
- Myanmar Yatai International Holding Group Co., Ltd. of Burma;
- Shwe Myint Thaung Yinn Industry and Manufacturing Company Limited of Burma;
- T C Capital Co Ltd of Cambodia; and
- Yatai International Holding Group Limited of Thailand.
https://home.treasury.gov/news/press-releases/sb0237
https://ofac.treasury.gov/recent-actions/20250908
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September 11, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating 32 individuals and entities and identifying four vessels in Treasury’s largest sanctions action to date targeting Iran-backed Ansarallah, commonly known as the Houthis. The networks targeted are part of the Houthis’ global illicit fundraising, smuggling, and weapons procurement operations, and include Houthi-associated companies, their owners, and other key Houthi operatives located in Yemen, China, the United Arab Emirates, and the Marshall Islands.
The following individuals have been added to OFAC’s SDN List:
- Al Faqih, Saddam Ahmad Mohammad of Yemen;
- Al Sharafi, Zaid Ali Yahya of Yemen;
- Al-Dawla, Mohammed Ahmed of Yemen;
- Al-Hammadi, Nasr Hussein of China;
- Al-Nahari, Hisham Abdulwasea Hael Mohammed of Yemen;
- Al-Nahari, Mohammed Abdulwasea Hael of China;
- Al-Shaer. Abdullah Mesfer Saleh of Yemen;
- Al-Suwaidi, Ibrahim Mohsen of Yemen;
- Dubaysh, Salih of Yemen;
- Khalil, Khaled Muhammad of Yemen; and
- Li, Ying, Linfen, Shaanxi of China.
The following entities have been added to OFAC’s SDN List:
- Al Faqih International Trade, Import, and Oil Services Limited of Yemen;
- Al-Hammadi Trading Shipping and Clearance Co., Ltd. of China;
- Azal Company of Yemen;
- General Holding Corporation For Real Estate Development and Investment of Yemen;
- Guangzhou Nahari Trading Co., Ltd. of China;
- Guangzhou Yakai International Freight Forwarding Co., Ltd. of China;
- Hubei Chica Industrial Co., Ltd. of China;
- Irtiqa For Development and Qualification Technical Institute of Yemen;
- Kamaran Industry and Investment Company of Yemen;
- MT Tevel Incorporated of the Marshall Islands;
- Oil Primer Company of Yemen;
- Royal Plus Petroleum Derivatives Import of Yemen;
- Sam Oil Company For Trade and Oil Services Ltd of Yemen;
- Shandong Mingming New Material Technology Co., Ltd. of China;
- Shanxi Shutong Import and Export Trade Co. Ltd. of China;
- Shenzhen Shengnan Trading Co., Ltd. of China;
- Silm Road Company For Trading and Importing of Yemen;
- Star MM Inc. of the Marshall Islands;
- Tyba Ship Management DMCC of the United Arab Emirates;
- Yemen Armored Comprehensive Security Services and Exhibitions Organization Company Ltd of Yemen; and
- Yiwu Wan Shun Trading Company Limited of China.
The following vessels have been added to OFAC’s SDN List:
- Black Rock (3E3938) Chemical/Oil Tanker Panama flag; MMSI 352986196;
- Nobel M (8P2547) Chemical/Oil Tanker Barbados flag; MMSI 314001017;
- Shira (V2YH8) Chemical/Oil Tanker Antigua and Barbuda flag; MMSI 304135000; and
- Star MM (V2YT5) Crude Oil Tanker Antigua and Barbuda flag; MMSI 305077000.
https://ofac.treasury.gov/recent-actions/20250911
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September 12, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on two Sudanese Islamist actors - Gebreil Ibrahim Mohamed Fediel (Gebreil) and the Al-Baraa Bin Malik Brigade (BBMB) - for their involvement in Sudan’s brutal civil war and their connections to Iran. These sanctions aim to limit Islamist influence within Sudan and curtail Iran’s regional activities, which have contributed to regional destabilization, conflict, and civilian suffering. The United States remains committed to working with regional partners to achieve peace and stability in Sudan, ensuring that the country does not become a safe haven for those who threaten Americans and the national interests of the United States.
The following individual has been added to OFAC’s SDN List:
- Fediel, Gebreil Ibrahim Mohamed of Sudan.
The following entity has been added to OFAC’s SDN List:
- Al-Baraa Bin Malik Brigade.
https://ofac.treasury.gov/recent-actions/20250912
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September 16, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a pair of Iranian financial facilitators and more than a dozen Hong Kong- and United Arab Emirates (UAE)-based individuals and entities for their roles in coordinating funds transfers, including from the sale of Iranian oil, that benefits the IRGC-Qods Force (QF), and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Iranian “shadow banking” networks like these—run by trusted illicit financial facilitators - abuse the international financial system, and evade sanctions by laundering money through overseas front companies and cryptocurrency. The IRGC-QF and MODAFL use these proceeds to support regional terrorist proxy groups and develop advanced weapons systems, including ballistic missiles and unmanned aerial vehicles (UAVs), which threaten the security of U.S. forces and those of our allies.
The following individuals have been added to OFAC’s SDN List:
- Alivand, Arash Estaki of Iran;
- Derakhshan, Alireza of Iran;
- Derakshan, Vahid of Iran; and
- Karimi, Leila of Iran.
The following entities have been added to OFAC’s SDN List:
- Alliance First Trading L.L.C of the United Arab Emirates;
- Alpa Hong Kong Limited of China;
- Alpa Investment L.L.C of the United Arab Emirates;
- Alpa Trading – FZCO of the United Arab Emirates;
- Everest International L.L.C of the United Arab Emirates;
- Minato Commercial Brokers of the United Arab Emirates;
- Minato Goods Wholesalers of the United Arab Emirates;
- Minato Investment L.L.C of the United Arab Emirates;
- Paul Ad Sons Trading FZE of the United Arab Emirates;
- Powell International FZE of the United Arab Emirates;
- Powell Raw Materials Trading L.L.C of the United Arab Emirates; and
- Unique Station Trading of the United Arab Emirates.
https://ofac.treasury.gov/recent-actions/20250916
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September 17, 2025: The United States remains committed to countering Iran, the world’s leading state sponsor of terrorism, and disrupting Iran-aligned militia groups (IAMGs) from conducting attacks against U.S. personnel and facilities. The Department of State announced the designations of IAMGs Harakat al-Nujaba, Kata’ib Sayyid al-Shuhada, Harakat Ansar Allah al-Awfiya, and Kata’ib al-Imam Ali as Foreign Terrorist Organizations (FTOs).
The following changes have been made to OFAC’s SDN List:
- Harakat Al-Nujaba of Iraq;
- Harakat Ansar Allah Al-Awfiya of Iraq;
- Kata’ib Al-Imam Ali of Iraq; and
- Kata’ib Sayyid Al-Shuhada of Lebanon.
https://ofac.treasury.gov/recent-actions/20250917
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September 18, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Sinaloa Cartel faction Los Mayos, along with the leader of the faction’s armed wing. These sanctions follow Under Secretary of the Treasury for Terrorism and Financial Intelligence John K. Hurley’s visit to the U.S.-Mexico border.
The following individuals have been added to OFAC’s SDN List:
- Arcega Aguirre, Candelario of Mexico;
- Brown Figueredo, Hilda Araceli of Mexico;
- Gonzalez Lomeli, Jesu of Mexico;
- Herrera Sanchez, Karlo Omar of Mexico;
- Herrera Sanchez, Mario Alberto of Mexico;
- Paez Pereda, Carlos Alberto of Mexico; and
- Ponce Felix, Juan Jose of Mexico.
The following entities have been added to OFAC’s SDN List:
- Alimentos y Diversion Insurgentes, S. DE R.L. DE C.V. of Mexico;
- Cavally Antro and Bar of Mexico;
- Coco Beach Bar, S. DE R.L. DE C.V. of Mexico;
- Complejeo Turistico JJ, S.A. DE C.V. of Mexico;
- Gotoco Alimentos Procesados S. DE R.L. DE C.V. of Mexico;
- Grupo Hotelero JJJ, S.A. DE C.V. of Mexico;
- Grupo JRCP, S. DE R.L. of Mexico;
- JJ Gonver S. DE R.L. DE C.V. of Mexico;
- JR Alimentos Del Mar, S. De R.L. De C.V. of Mexico;
- Los Mayos of Mexico;
- Operadora De Espectaculos, Alimentos y Bebidas J and R S.A. DE C.V.;
- Sabor Tapatio of Mexico;
- Sunset Servicios Gastronomicos DE R.L. DE C.V. of Mexico;
- Transporte Urbano y Suburbano Del V Municipio S.A. DE C.V.; and
- Veintiuno Mexicali, S. De R.L. DE C.V.
https://ofac.treasury.gov/recent-actions/20250918
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September 22, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Lex Instituto de Estudos Juridicos LTDA (Lex Institute) for its support to Brazilian Supreme Federal Court (STF) justice Alexandre de Moraes (de Moraes). De Moraes was designated by OFAC on July 30, 2025, for using his position to authorize arbitrary pre-trial detentions and suppress freedom of expression in Brazil. Also designated was Viviane Barci de Moraes (Viviane), de Moraes’ wife, who serves as the head of the Lex Institute.
The following individual has been added to OFAC’s SDN List:
- Barci Deo Moraes, Viviane of Brazil.
The following entity has been added to OFAC’s SDN List:
- Lex Instituto de Estudos Juridicos LTDA of Brazil
https://ofac.treasury.gov/recent-actions/20250922
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September 23, 2025: The Department of State designated Barrio 18 as a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT).
Barrio 18 is one of the largest gangs in our hemisphere and has conducted attacks against security personnel, public officials, and civilians in El Salvador, Guatemala, and Honduras.
The United States will continue to protect our nation by keeping illicit drugs off our streets and disrupting the revenue streams funding the violent and criminal activity of vicious gangs and drug cartels.
The following entity has been added to OFAC’s SDN List:
- Barrio 18 of El Salvador.
https://ofac.treasury.gov/recent-actions/20250923
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September 24, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Indian nationals, Sadiq Abbas Habib Sayyed and Khizar Mohammad Iqbal Shaikh, for their role in collectively supplying hundreds of thousands of counterfeit prescription pills filled with fentanyl and other illicit drugs to victims across the United States. OFAC also designated one India-based online pharmacy for its role in these criminal operations.
The following individuals have been added to OFAC’s SDN List:
- Sayyed, Saqid Abbas Habib of India; and
- Shaikh, Khizar Mohammed Iqbal of India.
The following entity has been added to OFAC’s SDN List:
- KS International Traders of India.
https://ofac.treasury.gov/recent-actions/20250924
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September 25, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five individuals and one entity for their role in generating illicit revenue for the Democratic People’s Republic of Korea (DPRK) government’s weapons of mass destruction (WMD) and ballistic missile programs, including by selling weapons to the Burmese military regime.
The following individuals have been added to OFAC’s SDN List:
- Aung, Tin Myo of Burma;
- Kim, Yong Ju of North Korea;
- Myint, Kyaw Thu Myo of Burma;
- Nam, Chol Ung of North Korea; and
- Oo, Aung Ko Ko of Burma.
The following entity has been added to OFAC’s SDN List:
- Royal Shune Lei Company Limited of Burma.
https://ofac.treasury.gov/recent-actions/20250925
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September 29, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 13O, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”.
GENERAL LICENSE NO. 13O: “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024”
- S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern standard time, January 9, 2026.