This newsletter is a listing of the latest changes in export control regulations through May 31, 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.
In this newsletter, we have added a specific DDTC FAQs section, we think this will be of interest to our readers.
REGULATORY UPDATES
Department of State, Directorate of Defense Trade Controls (DDTC)
Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses
May 2, 2025: 90 Fed. Reg. 17863: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=a69b87859759e21067b1791ad053af95 and
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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Bureau of Political-Military Affairs, Directorate of Defense Trade Controls: Notifications to the Congress of Proposed Commercial Export Licenses
May 2, 2025: 90 Fed. Reg. 17869: The Directorate of Defense Trade Controls and the Department of State give notice that the attached Notifications of Proposed Commercial Export Licenses were submitted to the Congress on the dates indicated.
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=6e9b87859759e21067b1791ad053af91 and
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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DDTC Final Commodity Jurisdiction Determinations Posted to Website
May 5, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following Final CJ Determinations for CJ’s adjudicated between September 12, 2024 through May 5, 2025, on its website at:
Readers may find these determinations helpful when performing self-classification work.
| Model Name | Manufacturer | Description | Final
Determination |
Final Determination Date |
| Dominate Virtual Anticipation Network, BUILD.2024.03.05.001 | BigBear.ai, LLC | Software that uses automated machine learning to provide anticipatory intelligence and decision support across a multi-domain environment | USML Category XI(b) | 9/17/2024 |
| ML-9600, ML-9600W, and ML-9600X Wideband High Frequency (HF) Transceivers; software versions 3.5, 3.6, 3.7, and 3.8 | Bronze Bear Communications, Inc., doing business as FlexRadio Systems | Software-defined radios | Seek a CCATS | 9/17/2024 |
| Marine Security Design Consulting Services | Ultrasea, Inc | Engineering design and analysis services for surface and subsurface security applications | Scenarios 1-3: Seek a CCATS
Scenario 4: Scenario 5: Defense service |
9/17/2024 |
| AVRA Suite | Arctos, LLC | Software suite that supports the lifecycle of flight safety analysis for airborne vehicles | Seek a CCATS | 9/17/2024 |
| 64 Megabit (8 M x 8-Bit) CMOS 3.0 Volt-only Uniform Sector Flash Memory, P/N Am29LV065DU90REI | Spansion, LLC | An unprogrammed flash memory device | Seek a CCATS | 9/29/2024 |
| Shock Tube, Model Number C4- 25658-050, Part Number C4- 25658-050 |
ITT Inc. | Inner tube for a shock absorber |
Seek a CCATS | 10/1/2024 |
| VT977 Integrated Processor/F PGA System, Model A, Part Number VT977-000- 000-000 |
Vadatech Inc. |
A system that integrates an Advanced RISC Machine (ARM) processor with an unprogrammed fieldprogrammable gate array (FPGA) module |
Seek a CCATS | 10/1/2024 |
| Rocky Linux, Model Number: Rocky Linux v8.5 and v8.9, Part Number: Rocky Linux Kernel v8.x | Hoonify Technologies Inc. | Open-source software operating system used to deliver the parallel computing software platform called TurbOSTM | Seek a CCATS | 10/4/2024 |
| Vulcan Basic Kit, Part Number VU0001, and Vulcan Projectile Combo Kit, Part Number VU0093 | Alford Technologies Ltd. | A versatile, modular, shaped charge designed for use in a variety of Explosive Ordnance Disposal (EOD) operations, that is inert until filled by the user, and projectiles for the shaped charge | Split: USML Category IV(c), Seek a CCATS | 10/4/2024 |
| Lenco BearCat Elevated Ramp Armored Vehicle | Lenco Industries, Inc. | Armored vehicle that transports 10-12 occupants and incorporates articulating rapid entry system | USML Category VII(e) | 10/22/2024 |
| RECU (Ruggedized Environmental Control Unit) | Mainstream Engineering Corporation | A portable heating, ventilation, and air conditioning (HVAC) system for temporary structures such as tents | EAR99 | 10/22/2024 |
| Panoramic Night Vision Goggle NVG-105 (without the image intensifier tubes), Model NVG-105 Rev B, Part Number 10011100-1 | Aether Optics LLC | NVG system consisting of the full mechanical, electrical, and optical systems (excluding the IITs), battery pack, and helmet mount | EAR99 | 10/22/2024 |
| ASM 509 Filled Shell Body, part number 01217926 | SAAB North America, Inc. | A projectile shell filled with PAX-47 explosives, but doesn’t include the fuze, fin, assembly, or nose cap | USML Category III(d)(4) | 10/22/2024 |
| MERLIN-I (Mounted Enhanced RADIAC Long-Range Imaging Networkable - Imager) | H3D, Inc. | An integrable detector and imaging module that is designed for high-resolution spectroscopy and isotope-specific imaging | USML Category XI(a)(4)(i) | 10/22/2024 |
| Aluminum Alloy Extrusion for Missile Container, Blueprint for Extrusion | Universal Alloy Corporation | Extrusion that will become a part for a missile storage container/launch tube, and a blueprint for this extrusion | CCL ECCN 9A604.x, CCL ECCN 9E604.a | 10/22/2024 |
| Metallic Hose Assembly, part numbers AE1002867H and AE100120H v.A | Danfoss Power Solutions II, LLC | Metallic, pneumatic hose assemblies | USML Category XX(c) | 10/25/2024 |
| Bullfrog, Part Number: BF001 | Allen Control Systems Inc. | Remote-controlled weapons station | USML Category XII(a)(1) | 10/25/2024 |
| GenesisRL, Model 0.1.4 | EpiSys Science, Inc. | Software used in video games to produce a top performing automated artificial intelligence (AI) agent by having different AI agents compete against each other | Seek CCATS | 10/27/2024 |
| Single Mode Laser Diode Bar Specification Model Number: 05082024/Rev. 1, Part Number 05082024 | Forward Photonics | Technical specification for a laser diode bar | USML Category XVIII(g) | 10/27/2024 |
| Distributed Spectrum Software Suite, Version Number 0.1 | Distributed Spectrum Inc. | Software capable of real-time RF signal detection, classification, and localization | Seek a CCATS | 10/27/2024 |
| Thrust Vector Controller Automated Test Equipment (ATE) Mk2, part number 24P-A75-100-001 | BAE Systems Australia Limited | Test Equipment for Missile Thrust Vector Controllers | USML Category IV(i) (software), USML Category XI(a)(7) (system prior to production), ECCN 9B604.d (system when in production) | 10/27/2024 |
| Model 86, ver. 1.7 | Oehler Research, Inc. | Acoustic Scoring System | USML Category IX(a)(1)(ii), USML Category IX(e)(1) (software), and CCL ECCN 0A614.a (sensors) |
11/16/2024 |
| Gulfstream model G700 aircraft with J-MUSIC SPS installed and used solely for Very Important Person or Head of State transport, and certain related information and services | General Dynamics Corporation | Aircraft modified to incorporate a Self-Protection Suite (SPS) without the SPS installed; Aircraft incorporating a SPS; Technical data and services necessary for the SPS installation and maintenance; Maintenance, repair, and other services to support continued safe operation of the modified aircraft; Information common to the unmodified G700 and the modified aircraft. |
Split Determination: Modified aircraft: USML Category VIII(a)(8) Aircraft with SPS: USML Category VIII(a)(8) Technical data and services directly related to the modifications: USML Category VIII(i); Technical data and services directly related to the installed SPS: USML Category XI(d); Services for the modified aircraft: USML Category VIII(i) for an (a)(8) aircraft; Information common to the civil G700 and the modified aircraft: Seek a CCATS |
3/12/2025 |
| RJ45 8-Channel A/B Port Switcher with RS232 ASCII Remote Control and Pushbutton Local Control, Model 7236, Part Number 306236 |
Electro Standards Laboratory, Inc. | A unit that enables the sharing of two RJ45 (A&B) ports for each of its eight channels, which allows switching for up to eight devices or networks. | EAR99 | 10/29/2024 |
| Knowledge Service Engine, Model Number: 4.1.2, Part Number: DMI-KSEC-1 | Discovery Machine Inc. | Execution framework for AI behavior models | EAR99 | 11/3/2024 |
| Two-day Simulated Experimentation Course and “Simulation Experimentation,” PowerPoint Presentation, version 5 | CogniPlay Dynamics, Inc. | A course that uses simulation for experimentation to advance armed force capabilities in future operational environments, as well as identify new synergies and opportunities | Service: USML Category IX(e)(3) Information: EAR99 |
11/16/2024 |
| Spectral Beam Combining Grating | Lawrence Livermore National Laboratory (LLNL) | An optical diffraction grating used in a directed energy weapon system | USML Category XVIII(e) | 11/16/2024 |
| EZRAM Raman Spectrometer, Model and Version Number EZRAM Plus Rev A, Part Number 12010 |
SSI LLC | A spectrometer used to identify unknown molecules through their vibration modes | Seek a CCATS | 11/16/2024 |
| Model 86, ver. 1.7 | Oehler Research, Inc. | Acoustic Scoring System | USML Category IX(a)(1)(ii) | 11/16/2024 |
| MAGCOMM | Precision Targeting, LLC | Wireless communication module - very low power, very short range (1 meter) for replacement of wired connections between electronic components |
USML Category XI(c)(2) (part number 52000125)
Seek a CCATS (part numbers 52000115 and 52000148) |
11/21/2024 |
| Vanguard, U.S. Navy Unmanned Surface Vessel, Model Number: Unmanned, USV-3, Part Number: USV - Vessel | Austal USA, LLC | A mid-size autonomous surface vessel | USML Category VI(c) | 11/21/2024 |
| Solidtron, part number SP205-01 | Excelitas Technologies Corp | Solid-state pulsed power switching thyristor device | USML Category IV(h)(9) | 11/28/2024 |
| Filter Electrical Connector, 38999 Series III, part number 21-50D015-35P | Amphenol Corporation | D38999 circular connector with added filter planar array component | USML Category VIII(f) | 11/28/2024 |
| MDS-10, Part Number 3130-0002 and MDS-10T, Part Number 3130-0005 | WM Industries Inc. | Handheld dual sensor detectors that combine metal detection and ground penetrating radar technologies for the purpose of detecting improvised explosive devices | USML Category XXI(a) | 12/19/2024 |
| Markes TT24-7NRT | CUBRC, Inc. | Test data from a commercial product that is a near real-time vapor sampling system for chemicals | Seek a CCATS | 11/29/2024 |
| Digital Acquisition Toolset V1.0 | Ricardo, Inc. | Software tools designed to establish an enterprise framework for lifecycle digital engineering. | CCL ECCN 5D002.c.1 | 11/29/2024 |
| Titanium Fire Pump, Part Number: 5773203, Schematic Number: 803-5773203, Technical Manual: S6255-W6-MMA-010 | Carver Pump Company | A titanium centrifugal fire pump and its schematic and technical manual | Pump: CCL ECCN 8A609.x Manual: CCL ECCN 8E609.a Schematic: Seek a CCATS |
11/29/2024 |
| HALIA, Model Number: Alpha Prototype, Part Number: v2; Hoverfoil Wings | LeVanta Tech Inc. | Sea-launched aerial drone and its Hoverfoil wings | EAR99 | 11/29/2024 |
| Embedded Field Programmable Gate Array Intellectual Property (eFPGA), Part Number K6N10 | QuickLogic | Family of unprogrammed eFPGA IP architecture | Seek a CCATS | 11/29/2024 |
| AgileAir-78, Model Number: 78 | Oshkosh Corporation | A portable diesel-powered unit designed to provide ground services to military aircraft | CCL ECCN 9B610.a | 11/29/2024 |
| BuildOS, Version: 1 | Dirac, Inc. | An automated work instruction platform that drafts instructions for hardware assembly | EAR99 | 11/29/2024 |
| Spherical Bearing, Part Number MLAM4016 | NMB (USA) Inc. | A component of the TP400 aircraft propeller used for blade pitch adjustment and feathering | CCL ECCN 9A610.x | 12/8/2024 |
| Spherical Bearing, Part Number KNDB22-12/287600 | Sargent Aerospace and Defense, LLC | Spherical bearing for an aircraft landing gear | USML Category VIII(h)(1) | 12/8/2024 |
| 3X3 LSD, Version 1, Part Number HMCS-MK6X-LSD-3X3, and 6X3 LSD, Version 1, Part Number HMCS-MK6X-LSD-6X3 | Haivision MCS LLC | Multi-display video walls created by joining multiple display screens together in harsh environments | CCL ECCN 8A609.x | 12/8/2024 |
| Arcas Maritime Domain Awareness System | BigBear.ai, LLC | Data analytics software for maritime domain awareness | USML Category XI(b) | 12/8/2024 |
| Encore Flight Software, initial release | Odyssey Space Research, LLC | Flight software framework designed for safety critical components in spacecraft and satellites, providing essential functionality for communication, navigation, control, data processing, and other space-related applications | Seek a CCATS | 12/8/2024 |
| Composition A-5 Explosive, Model Composition A-5 | US Army Armament Research, Development and Engineering Center (ARDEC) | An explosive compound containing RDX | USML Category V(a)(23) | 12/8/2024 |
| M2E Acoustic Modem, Part Number M2E-S115 | OceanComm Incorporated | Device that provides high-speed wireless connectivity underwater | CCL ECCN 5A001.b.1.a | 12/8/2024 |
| Voxaverse, Part Number 1001 | 10x National Security | Software that provides chat, voice, video, and file sharing in a fully encrypted multi-user environment | CCL ECCN 5D002.c.1 | 12/8/2024 |
| Aluminum Mirror, Part Number: C1735 | Inrad Optics, Inc. | A component of the Scanner Module of the Electro-Optical Observation System (EOOS) for Military Vehicles | USML Category XII(e)(18) | 12/11/2024 |
| SignalQ Event Detection, Part Number GEOL-0020 | NVRN, LLC d/b/a | A software-only signal intelligence platform that provides event-detection capability that leverages freely associated mobile phones as sensors |
USML Category XI(d) | 12/11/2024 |
| Integrated Unique Identification (IUID) | Intrinsic Marks International | MIL-STD-130 compliant identification name plates with a range of thicknesses from .003” to .032” and used on the F-35 | Seek a CCATS | 12/13/2024 |
| DDM4/DD5 Armorers Manual | M. C. Daniel Group Inc. | A manual for armorer certification for the Daniel Defense (DD) DDM4 and DD5 rifle lines. | USML Category I(i) | 12/13/2024 |
| 1) Technical data for the design of the H225M Flight Simulator, Iteration: January 1, 2018 through December 31, 2020 2) Technical data for the design of the of H225M Flight Simulator, Iteration: January 1, 2021 the present |
FlightSafety International, Inc. | Information related to the Design of the H225M Flight Simulator | USML Category IX(e)(1) | 12/13/2024 |
| Nitronic 60 High Strength Stainless Bar, Model Number: UNS S21800, ultra high strength, Part Number: A06200050004 (sample PN) | High Performance Alloys Inc. | Material used to make bushings for an aircraft | Seek a CCATS | 12/13/2024 |
| Positive Displacement External Gear Coolant Pump, Model GB-P34-DC30B | Micropump, Inc. | Submarine component | USML Category XX(c) | 12/13/2024 |
| Air Conditioner, Model A/M32C-10C, Part Number 100502-2 | American Turbo Systems | Used with a ground start cart to provide conditioned air to aircraft | Seek a CCATS | 12/13/2024 |
| NATO Resilience and Crisis Management Consulting Service, Model Number: CBI-Resilience-Consulting-01 v1.0 | Capacity Building International | Consulting services focused on NATO resilience, emergency management, and crisis response. | Seek a CCATS | 12/13/2024 |
| High-Temperature Material Characterization System, Model Number: HTMC150-150, Part Number: DSC1547 | Delta Sigma, LLC | 8-40 HGz free-space material characterization system for temperatures up to 1,500 °C. | EAR99 | 12/13/2024 |
| Microcircuit, Pulse Width Modulation (PWM), Current Mode with J-Leads, Model: 561R911 revision E, Part Number: 561R911H03 | Corfin Holdings Inc. | A current mode, pulse-width modulation, controller chip with solder coated leads modified to add J-Leads. | Seek a CCATS | 12/13/2024 |
| HI-TAK Conductive Gasket with Knitted Aluminum Mesh, Model: Revision A, P/N: PG339000-73 | Aviation Devices and Electronic Components LLC | Gasket used to seal and moisture proof between overlapping surfaces, providing environmental protection and electrical conductivity. | EAR99 | 12/19/2024 |
| 1. MAN-PC software, Version 5.0.1.5; 2. MAN-PC Software Activation License; and 3. Silvus StreamCaster radios with MAN-PC software included | Silvus Technologies, Inc. | An activation license and software option for StreamCaster radios. | 1, 2: USML Category XI(d) 3: USML Category XI(a)(5)(iii) | 12/19/2024 |
| Pressure Gauges, Part Numbers 97200003533 and 97200003534 | WIKA Holding, LP | Pressure gauges used in an air-toair refueling system. | Seek a CCATS | 12/20/2024 |
| OwlEye | Omitron, Inc | A service for satellites that helps assess and mitigate the risk of collisions with other space objects. | Seek a CCATS | 12/20/2024 |
| Neros Valkyrie UAV, Block 1 | Neros Technologies | First-person view drone carrying a 3 kg payload. | USML Category VIII(a)(16) | 12/20/2024 |
| Image Signals Processing Board | Sheltered Wings, Inc. d/b/a Vortex Optics | Printed circuit board assembly for processing images. | USML Category XII(e)(19) | 12/20/2024 |
| SPX-500 and SPX-800, Part Numbers 950058, 950061, 950062, and 950064 | Senspex, Inc. | Visible and MWIR Camera Systems | Seek a CCATS | 12/29/2024 |
| Services that Include the Loading of Production Parts and Alignment of Production Tooling for Blisks | Manufacturing Technology, Inc. | Assistance in the setup and use of production equipment and tooling for the purpose of producing Blisks | For Blisks described in USML Category XIX(f): USML Category XIX(g) For Blisks not described on the USML: Not a defense service | 12/29/2024 |
| FEKO 2019 (Standard), Certain FEKO 2019 Enhancements, and FEKO Enhanced 2019 | Altair Engineering, Inc. | Software to evaluate the emissions of electromagnetic energy | Foreign defense articles described in USML Category XIII(i)(4) | 12/29/2024 |
| CF-104 Starfighter Display Aircraft, Model F-104, Serial #: 683A-1031 | Canadair | Demilitarized and mutilated fighter aircraft with all articles described on the U.S. Munitions List removed and cuts to the airframe to prevent it from being made airworthy. | CCL ECCN 9A610.x | 12/30/2024 |
| Performance Requirements, Testing Services, and a Fuel Cell, Version V1.0 | Piasecki Aircraft Corporation | High Temperature Proton Exchange Membrane (HTPEM) Hydrogen Fuel Cell for Aviation | Fuel Cell: USML Category XI(a)(7); Services and Information: USML Category XI(d) |
12/30/2024 |
| CF-116 Freedom Fighter Display Aircraft, Model CF-5D, Tail Number 116809 | Canadair | Demilitarized and mutilated fighter aircraft with all articles described on the U.S. Munitions List removed and cuts to the airframe to prevent it from being made airworthy. | CCL ECCN 9A610.x | 12/30/2024 |
| Ballistic Performance Testing and Test Results | Avient Protective Materials LLC | Testing of composite armor panels to the National Institute of Justice (NIJ) Standard 0101.07 RF1 and RF2 levels, including performing the testing and providing test results | USML Category XIII(I) | 12/30/2024 |
| WR112 Circulator, Part Number XC3-73 | Microwave Techniques, LLC | A circulator used in a radar subsequently used in the Thales Goalkeeper Close-in Weapon System (CIWS). | USML Category VI(f)(7) | 12/30/2024 |
| Pistolet-Pulemyot Sudayeva "PPS43" 7.62mm x 25mm Submachine Gun | Minutemen Defense LLC | Fully Automatic Submachine Gun | USML Category I(b) | 12/30/2024 |
| Schematic ES-5000 for Cable assembly CX2384 | Elbit Systems UK Limited | Schematic depicting a data transfer cable assembly | Seek a CCATS | 12/30/2024 |
| EnQuanta Base Suite of products (Vault, Storage, Transfer, and Comms), Model Number: Base V1.0.1 | VoiceIt Technologies, Inc. (dba EnQuanta, A VoiceIt Technology Company) |
Quantum resilience hybrid cryptographic object code used to provide “incryption” (sic) of digital assets | CCL ECCN 5D002.c.1 | 12/30/2024 |
| Plain Encased Seal, Part Number 3233429‐2 | Quality Industrial Products, Inc. | A component to a thrust reverser actuation system (TRAS) used in the Rolls Royce RB211 turbofan engine | CCL ECCN 9A991.d | 12/30/2024 |
| GCA 2000/2020 Radar, Model GCA 2000, (Multiple Part Numbers); MPN-25 Radar, Model MPN-25 BUILD, (Multiple Part Numbers); and AN/MPN-25 Radar, Part Number 276000-1 | L3 Harris Technologies, Inc., d. b. a. Space and Airborne Systems | Surveillance radars with Identification Friend or Foe (IFF) and Moving Target Detector (MTD) features | USML Category XI(a)(5)(ii) | 12/30/2024 |
| RATTLER UAS, Model Number RATTLER.UAS.V1 | Actualized Business Solutions, Inc | Unmanned aerial system (UAS) target drone used to support test and evaluation and training of counter UAS systems | USML Category VIII(a)(10) | 1/30/2025 |
| Related to Wire Rope Isolator, Model Number: WR28, Part Number: WR2880004BM | ITT Inc. | Advice regarding installation of the product on a fire control system component | USML Category XII(f) | 1/30/2025 |
| Monofilament Vaporization Propulsion (MVP) System | CU Aerospace, LLC | Thruster for small satellites | Seek a CCATS | 1/30/2025 |
| Cubesat High Impulse Propulsion System (CHIPS) | CU Aerospace, LLC | Propulsion System for Small Satellites | Seek a CCATS | 1/30/2025 |
| Rayon Based Carbon Fabric, CCA-10 | Tex-Tech Industries, Inc. | Rayon Based Carbon Fabric | Seek a CCATS | 2/9/2025 |
| Periscope Prism Drawing Numbers: 12548771 and 12548772, and Process Specifications: 1247300 | Global Photonics, Inc. | Drawings and process specifications for the manufacture of glass prisms for a periscope | USML Category XII(f) | 2/9/2025 |
| QuickShot v8.0.2, Part Number QS-XX-XX_CVI4B | SpaceWorks Enterprises, Inc. | Trajectory Optimization Software | EAR99 | 2/10/2025 |
| Antenna, Part Number S67-1575-714 | Sensor Systems, Inc. | M-Code capable antenna | USML Category VIII(f) | 2/10/2025 |
| SeaFLIR / TacFLIR 230, SeaFLIR / TacFLIR 240, and SeaFLIR / TacFLIR 280-HD | Teledyne FLIR, LLC | Electro-optical imaging systems with gimbal stabilized 9” turrets | USML Category XII(c)(3) | 2/10/2025 |
| Veronte Autopilot, Model 1x, Version 4.8, Part Number P008726 | Embention Sistemas Inteligentes SA | User-programable controller for the operation of autonomous devices such as drones, ground vehicles, robots, and surface vehicles | Seek a CCATS | 2/10/2025 |
| Automated Portable Raman Microscope (Pendar XM); Pendar XM with Chemical Warfare Agent (CWA) Library; Pendar XM Software; Pendar XM Source Code and Technical Drawings; and Pendar XM Non-CWA Spectral Library | Pendar Technologies LLC | Portable system designed for testing items to detect explosive or drug residues, and, when equipped with the CWA library, certain chemical warfare agents, without contact or damage to the item under test, and related technology | Seek a CCATS | 2/10/2025 |
| Spherical Bearing Assembly, Part Number KSC255619B | Kaman Corporation | Component of the tail hook actuator of a fighter aircraft | USML Category VIII(h)(5) | 2/13/2025 |
| X-Wall MX+ XN SATA Gen 3 Crypto Module Solution, Part Number X-Wall MX+ xN / x/I with Firmware version 3.8 | Enova Technology Corp. | An application-specific integrated circuit (ASIC) engineered for encryption and decryption of standard SATA (Serial Advanced Technology Attachment) storage devices, with a maximum data transfer rate of 6 Gbps | Seek CCATS | 2/13/2025 |
| Electric Motor Resolver, Part Number: 433283 | Parker-Hannifin Corporation | A rotational position measurement device for use in a hydraulic pump electric motor | USML Category VIII(h)(1) | 2/13/2025 |
| Mine Eraser | Ensign-Bickford Aerospace & Defense Company | An energetic line charge containing plastic bonded explosive blocks connected by detonating cord | USML Category IV(c) | 2/13/2025 |
| N5193A UXG Firmware and Field Programmable Gate Arrays (FPGAs) (Version A.01.90) and N5194A UXG Firmware and FPGAs (Versions A.02.00 and A.12.00) | Keysight Technologies, Inc. | Firmware and FPGAs for N5193A and N5194A UXG signal generators | UXG Firmware: USML Category XI(d)
FPGAs when programmed with FPGA images loaded: USML Category XI(c)(1) Unprogrammed FPGAs: Seek a CCATS Preprogrammed CPLDs: Depends on the export classification of Keysight MXG signal generators |
2/13/2025 |
| LED cable assembly, part number P567847 | Axon' Cable | Wiring harness with 16 AWG and 24 AWG insulated wire | USML Category VIII(h)(1) | 2/13/2025 |
| Diced and Undiced Integrated Circuit Wafers | Skadden, Arps, Slate, Meagher & Flom LLP | Cut and uncut unpackaged integrated circuits programmed for defense articles | USML Category XI(c)(1) | 2/13/2025 |
| 5 cm x 5 cm Sapphire Substrate and related information | Luxium Solutions, LLC | A transparent, single crystal aluminum oxide substrate that does not exceed the dimensions in USML Category XIII(e)(3) for transparent ceramic plate | EAR99 | 2/18/2025 |
| Artificial Intelligence Security Platform (AISec Platform) Software, Version 24.10.0 | HiddenLayer, Inc. | Security solution to protect AI systems from threats throughout their lifecycle by detecting and responding to risks like malicious inputs and weaknesses in the AI’s underlying components, data sources and development tools | Seek a CCATS | 2/18/2025 |
| TrueView R40i Radars, Part Numbers TV-R40iSC, TV- R40iSC+1YSUP, TVR40iSC+SWL+3YS, TV-R40iMC, TV-R40iMC+1YSUP, TVR40iEC+SWL+1YS, TVR40iEC+ SWL+3YS, TV-R40iEC-2.0+1YSUP, and TV-R40iEC, TVR40iMC+ SWL+1YS, TVR40iMC+SWL+3YS |
Fortem Technologies, Inc. | Active Electronically Scanned Array (AESA) radars designed for drone detection and airspace security and operating in the KU-Band (15.4-16.6 GHz) with between 16-22 W of power | CCL ECCN 6A008.e | 2/18/2025 |
| Power Supply HV/LV, Version Number: REV D, Part Number: 580470 | Shigamo Development, Inc. dba: American High Voltage |
Power supply for a heads-up display | CCL ECCN 9A610.x | 2/18/2025 |
| G‐Loc and GD-Loc Geolocation and Object Positioning Software for Gimbals | Trillium Engineering, LLC | Software tools that provide improved geolocation accuracy and precise object positioning | Seek a CCATS | 2/18/2025 |
| GeoDLSR, Version Number: 1.0 and XEN-HUB, Version Number: 1.0 | OnOff Block Inc./Xenesis | A space-based network routing software and a Dual Aperture Optical Head Assembly | ECCN 9A515.x/ ECCN 9D515.a | 2/18/2025 |
| Soft Telepresence System software, STS Phase 0, Version v.0 | Kansas State University | Software that uses augmented reality (AR) to enable a "share what you see" telepresence experience to enhance collaboration by transferring audio and visual input from a remote operator to another person | Seek a CCATS | 3/1/2025 |
| S9-Type Laser Diode Array, Model: S9 | Leonardo Electronics US, Inc. | Laser diode array that has a thermally conductive base that can incorporate up to 10 high power edge-emitting laser diode bars | USML Category XII(e)(2) | 3/1/2025 |
| LEUSI Fiber Amplifier, Model Number: A-40, Part Number: 01-1111 | Leonardo Electronics US Inc. | A 2.5 kW continuous wave operation fiber amplifier with narrow linewidth and single output | USML Category XVIII(e) | 3/5/2025 |
| Merlin-Handheld-SM and Sidemate, Model 114401-1-4-0, PN 114401-1-4-0 | Iris Technology Company | Interfaces between a PRC-163 radio system, a PRC-163 battery, an external power source, and auxiliary equipment to power those items | CCL ECCN 3A611.x | 3/10/2025 |
| ARES Lenco BearCat, Model ARES Lenco BearCat 2024 | Lenco Industries, Inc. | Off-road capable armored personnel carrier | USML Category VII(e) | 3/6/2025 |
| Rechargeable, Nickel Cadmium Battery, model BB-287 | ENERSYS | Provides power for the target acquisition and fire control system of a missile system | USML Category XII(e)(1) | 3/6/2025 |
| ConductorOS | BigBear.ai, LLC | A software system that enables rapid decision-making and distributed computing by orchestrating data and AI in near real-time, allowing interoperability across diverse environments and easy integration of legacy systems with modern applications | Seek a CCATS | 3/6/2025 |
| Project Pantheon | Resilience Government Services, Inc. | Technical information relating to monoclonal antibodies (mAb) or prophylaxis of exposure to aerosolized botulinum neurotoxin A and B serotypes | Not subject to the ITAR or the EAR | 3/6/2025 |
| Common Aperture Laser Illuminator Laser Diode Module (LDM) and Common Aperture Laser Pointer LDM | Teledyne Technologies Incorporated | Modules for a laser illuminator and a laser pointer, each used in gimbaled electro-optical surveillance systems | USML Category XII(e)(8) | 3/12/2025 |
| High Voltage Power Supply, Model Number: dB-2560 | dB Control | A high voltage power supply designed and adapted from the commercial Ka-band and high-power amplifier to work with the Leonardo ET9900 TWT. | USML Category XII(e)(1) | 3/12/2025 |
| Uniform Crystals Test Sensors (UCTS) Testing Service and Resulting Test Information | LG Tech-Link Global, LLC | Testing and analysis of material sensors to determine the maximum temperatures the sensors were exposed to | Split based on the application.
Defense service and technical data (see definitions) EAR99 when not a defense service or technical data |
3/12/2025 |
| M3A1 Pull Wire Fuse Lighter, Model Number: M3A1, Part Number: 1050 | Martin & Shaft LLC | Fuse lighter (igniter) for activating ground burst simulators and grenade simulators | Seek a CCATS | 3/12/2025 |
| RoadBlock, Vehicle Interdiction Cartridge, MOD 0 | Matsys Inc | Shotgun shell containing reactive metals that release thermal energy |
USML Category III(a)(3) | 3/12/2025 |
| Auxiliary Power Unit (APU) Exhaust, part 461-30001 | Senior Operations, LLC | An auxiliary power unit exhaust duct that is designed for an aircraft in development | USML Category VIII(f) | 3/12/2025 |
| PowerLight System | PowerLight Technologies | System that uses a laser to transmit power between a transmitter device and receiver device | USML Category XI(a)(7) | 3/16/2025 |
| Multi-Shot Robotic EOD Disruptor (MRED) Version 5.1 | Vadum, Inc. | Electronically controlled disruptor capable of firing existing 12-gauge disrupter cartridges and water shots |
Seek a CCATS | 3/16/2025 |
| ARTIV, Model Number: 1.x | DEFCON AI, INC | Modeling, simulation, and analysis simulation software to support mobility and logistics | USML Category IX(b)(4)(iii) | 3/16/2025 |
| Aloft X-band Radars, Model: AXR-112-UL-E, SDRT v1; AXR-122-UL-E, SDRT v2; AXR-112-Max-E, SDRT v1; and AXR-122-Max-E, SDRT v2 | Thomsen and Burke LLP | Miniature X-band Synthetic Aperture Radars (SAR) used for mid-sized drones, aircraft, and stratospheric vehicles | USML Category XI(a)(3)(ii) | 3/16/2025 |
| Mini DDL Transceiver | Aerovironment, Inc. | Communications Transceiver | USML Category XI(a)(5)(i) | 3/16/2025 |
| OmniBlast Air, Part Number 01, Model Number OBA; OmniBlast Air+, Part Number 00, Model Number OBA+; OmniBlast Air and OmniBlast Air+ Consulting Services |
Advanced Materials and Devices | Wearable blast sensors and associated consulting services | USML Category X(a)(8) until sensors are in production
USML Category X(e) for services while sensors are in development USML Category IX(e)(3) for services when not directly related to a defense article |
3/16/2025 |
| Schematic of Receiver Integration Fixture (RIF), Part Number TYPII_BREAKOUT_REVB | Navigation Technology Associates, Inc | Schematic showing a device used to test GPS receivers | Seek a CCATS | 3/21/2025 |
| RAID Plate Chassis | AeroVironment, Inc. | A chassis, or "spine," that is worn on the back of a UAV operator, holds four modular radios, and provides AI-enhanced common control, open architecture, and advanced networking supporting a complex multi-radio layout. | Seek a CCATS | 3/21/2025 |
| Fortem DragonFly, Model DragonFly X100 | Fortem Technologies, Inc. | Multi-copter with an onboard radar and customizable user module. | CCL ECCN 6A008.e | 3/23/2025 |
| MRAM Radiation hardened memory device | Western Digital Technologies, Inc. |
Non-volatile device that stores data in magnetic domains. | Seek a CCATS | 3/31/2025 |
| Non-destructive Testing Consulting Services (NDT) | TB3 NDT Consulting LLC | Training and subsequent certifications on NAS-410, SNT-TC 1A, and ANSI/ASNT CP-189 standards. | Seek a CCATS | 3/31/2025 |
| Audio Routing Circuit Card with Transit Firmware Installed, Model 6-Channel, Part Number 874-2040-002 (Firmware Version 874-9F01-001) | TTM Technologies, Inc. | Circuit card assembly that performs analog-to-digital and digital-to-analog conversions | USML Category XI(c)(2) | 3/31/2025 |
| TAMP Austere, version: 01 | GAMS Inc. | Advanced tactical medical training that includes training to return fire to neutralize the enemy while performing initial life-saving interventions, using firearms to establish and maintain a secure cordon around a medical team, and training on the use of certain of defense articles | USML Category IX(e)(3) | 3/31/2025 |
| Test Stand, Model 1, Part Number 0001 | JINXIN INC | Test Stand | Seek a CCATS | 4/7/2025 |
| TF50A Gas Turbine Engine with SPG Power Turbine, Part Number 0-001-010-76; SPG Power Turbine, Model SPG4PT-SN, Part Number SPG4PT-SN-001; Inconel Spacer, Part Number SPG-141-55; Inconel Exhaust Diffuser, Part Number SPG-051-02 |
Signal Power Group Operating LLC | Marine gas turbine engine with power turbine derived from Honeywell T55-GA-714A kit and two custom components | Engine: CCL ECCN 9A619.a; Power Turbine and Spacer: 9A619.x; Exhaust diffuser: 8A609.x |
4/9/2025 |
| Harness, Protected-Side, Left Main A, Model D, Part Number 51586-0101 | Collins Aerospace | Wire harness for in-tank fuel quantity indicating system | USML Category VIII(h)(11) | 4/14/2025 |
| Photothermal Common-path Interferometer, Model and Part Number PCI-003; and Testing Service | Island Interferometry | A machine that measures thermal absorption in optical materials using a laser, and related services | Interferometer: Seek a CCATS; Testing service: Split; defense service when testing a defense article |
4/14/2025 |
| M107 Simulated 155 Artillery Round; M9 Charge bag; and M582 Simulated Fuze | Van Halteren Technologies | Simulated ammunitions that replicate the weight and balance of artillery rounds, charge bags, and fuzes | ECCN 0A614.x | 4/14/2025 |
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DDTC Name And Address Changes Posted To Website
May 2 through May 30, 2025: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in Address of Curtiss-Wright Controls Integrated Sensing Inc. from 1150 North Fiesta Boulevard, Gilbert, AZ 85233 to 1100 W Gove Pkwy, Ste. 102, Tempe, AZ 85283;
- Change in Address of GTDS America, LLC from 8 Morgan Avenue, Newbury, MA 01951 to 10 Trailside Way, Norfolk, MA 02056;
- Change in Name of Airbus GmbH sites in Ausburg and Varel due to corporate restructuring;
| From: | To: |
| Airbus GmbH | Airbus Aerostructures GmbH |
| Airbus GmbH Plant Ausburg | Airbus Aerostructures GmbH Plant Ausburg |
| Airbus GmbH Plant Varel | Airbus Aerostructures GmbH Plant Varel |
- Change in Address of GE Aviation Czech s.r.o from Beranovych 65, 199 02, Letnany, Prague 19902, Czech Republic to Berabovych 65, Praha 9, Praha 199 02, Czech Republic;
- Change in Address of a branch of GE Aviation Systems North America LLC from Building Number 7546, Qurtubah District, Unit 1110, Riyadh 13244, Saudia Arabia to Building Number 7546, Qurtubah District, Unit 1110, P.O. Box 2284, Riyadh 13244, Saudi Arabia;
- Change in Address of GE India Industrial Pvt. Ltd. from A-18 First Floor, Okhla Industrial Area, Phase II, New Delhi, India 110 020 to Unit 9, First Floor, Hyatt Delhi Residences, Aerocity, New Delhi, India 110 037; and
- Change in Address of GE Aviation Systems North America LLC from 21 Leonardo Da Vinci St., Tel Aviv 6473319, Israel to 8 Shaul Hamelech Blvd., Tel Aviv 6473307, Israel.
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DDTC Frequently Asked Questions (FAQs)
Q: I am exporting software source code. Are there any additional requirements I need to be aware of?
A: Yes. Any export of U.S software source code, operating algorithms, signal processing algorithms, and/or program maintenance documentation must be compliant with DoD Guidelines for International Transfers of Software Documentation (including source code), dated 8 April 1997. The request MUST include a full description and explanation of all relevant software modules. Be sure to identify the modules proposed for release, as well as those that will NOT be released. Contact DTSA for a copy of the guidelines or answers to any questions you may have.
Q: Why is a transmittal letter required if information is already stated in application?
A: While the transmittal letter may re-state information already provided in the application, it will allow the applicant to provide further insight into the transaction as well as provide information not specifically required in the license application, i.e., related voluntary disclosure (VD), customs seizure. More importantly, DDTC is moving away from the “stand-alone” license application where no supporting documentation is provided. The inclusion of a transmittal letter re-stating the application information or providing further clarification of the transaction allows for a more robust license file.
Q: My company is entering into an agreement to grant a non-US person authorization to manufacture defense articles abroad. The agreement requires the transfer of ITAR-controlled technical data, defense articles, or the performance of defense services, but we are not transferring manufacturing know-how. Is an MLA still required?
A: Yes. ITAR § 120.57(d) provides that an MLA is an agreement “whereby a U.S. person grants a foreign person an authorization to manufacture defense articles abroad” and involves either (1) exports of defense articles, including technical data, or the performance of a defense service, or (2) the use by the foreign person of technical data or defense articles previously exported by the U.S. person. Thus, an MLA would be appropriate even if no manufacturing know-how is transferred. DDTC may authorize a manufacturing activity under a TAA when it meets all the conditions of ITAR § 124.13 and only limited defense services are furnished (e.g., quality control). Alternatively, if no defense services will be furnished and all the conditions of ITAR § 124.13 are met, an offshore procurement license may be appropriate.
Q: How is a purchase order issued to a subsidiary handled in the license application?
A: The parent company who is the holder of the registration code must be identified in the applicant section of the license application. If the supporting documentation is issued to or identifies a subsidiary of the parent, the subsidiary’s information must be provided in the subsidiary section of the applicant block.
Q: Is an export license required in order to send defense articles to Puerto Rico?
A: No. As ITAR § 120.60 makes clear, Puerto Rico is part of the United States, as are other locations including American Samoa, Guam and the U.S. Virgin Islands. No export occurs when a defense article is shipped to Puerto Rico. Therefore, no export license or other approval from DDTC is required.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia
May 2, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy one thousand (1,000) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM) and fifty (50) AIM-120C-8 AMRAAM guidance sections. The following non-MDE items will also be included: AMRAAM control section spares, missile containers, and support equipment; spare parts, consumables, accessories, and repair and return support; weapon system support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $3.50 billion. The principal contractor will be RTX Corporation, 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 Ukraine
May 2, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Ukraine requests to buy equipment and services in support of its F-16 aircraft. The following non-MDE items will be included: aircraft modifications and upgrades; personnel training related to operation, maintenance, and sustainment support; spare parts, consumables and accessories, and repair and return support; ground handling equipment; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $310.5 million. The principal contractors will be Valiant Integrated Services, located in Herndon, VA; Top Aces Corporation, located in Mesa, AZ; Lockheed Martin Aeronautics, located in Fort Worth, TX; Pratt and Whitney, located in East Hartford, CT; Snap-on, Inc., located in Kenosha, WI; BAE Systems, Inc., located in Falls Church, VA; AAR Corporation, located in Wood Dale, IL; and Comsetra, LLC, located in Grove, OK. 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
May 2, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Norway has requested to buy three hundred (300) AIM-9X Block II Sidewinder tactical missiles; two (2) AIM 9X Block II special air training missiles (NATM); twenty-four (24) AIM 9X Block II captive air training missiles (CATM); twenty (20) AIM 9X Block II Tactical Guidance Units; and twenty (20) AIM 9X Block II CATM Guidance Units. The following non-MDE items will also be included: dummy air training missiles; missile 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 program cost is $370.9 million. The principal contractor will be RTX Corporation, 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 the Czech Republic
May 5, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the Czech Republic has requested to buy AN/PYQ-10A(C) simple key loaders; AN/PRC-160, AN/PRC-163, and AN/PRC-167 radios; RF-300M-DL(C) small secure data links and support equipment; spare parts; U.S. Government and contractor technical engineering, logistics, and personnel services; and other related elements of logistics and program support. The estimated total program cost is $181 million. The principal contractor will be L3Harris Global Communications, Inc., located in Rochester, NY. At this time, the U.S. Government is not aware of any offset agreement proposed in connection with this potential sale. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To the United Arab Emirates
May 12, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the United Arab Emirates (UAE) has requested to buy six (6) CH-47F Block II Chinook helicopters with air-to-air refuel probe capability and extended range fuel tanks; sixteen (16) T-55-GA-714A engines, (12 installed, 4 spares); fourteen (14) Embedded Global Positioning System (GPS)/Inertial Navigation System (INS) (EGI) devices with M-Code (12 installed, 2 spares); eight (8) AN/AAR-57 Common Missile Warning Systems (CMWS) (6 installed, 2 spares); twenty (20) AN/ARC-231A communications security (COMSEC) radios (18 installed, 2 spares); and twenty (20) M-240 machine guns (18 installed, 2 spares). The following non-MDE items will also be included: Common Missile Warning System (CMWS) classified software; AN/APR-39A radar warning receivers; AN/AVR-2B Laser Detecting Sets (LDS); AN/ARC-220 high frequency (HF) radios; KY-100M COMSEC terminals; aircraft survivability equipment (including impulse cartridges for cable cutters and aircraft cartridges); AN/ARN-147 Very High Frequency (VHF) Omni Directional Radio Range/Instrument Landing System (VOR/ILS) receivers; WESCAM MX-15HDi electro-optical/infrared imaging systems; AN/ARN-153 Tactical Airborne Navigation System (TACAN) radios; AN/APN-209 radar altimeters; AN/APX-123A identification friend or foe (IFF) transponders; KIV-77 COMSEC IFF cryptographic appliqués; AN/PYQ-10 Simple Key Loaders; services to support the mission equipment; hardware and services required to implement partner-unique modifications; Fast Rope Insertion/Extraction Systems (FRIES); Internal Extended Range Fuel Systems (ERFS); in-flight refueling capability; firefighting equipment; ballistic armor protection systems; air worthiness support; spare and repair parts; communications equipment; personnel training and training equipment; site surveys; tool and test equipment; ground support equipment; repair and return; publications and technical documentation; Quality Assurance Team (QAT); 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 $1.32 billion. The principal contractors will be Boeing Helicopter Aircraft Company, located in Ridley Park, PA; and Honeywell Engine Company, located in Phoenix, 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 the United Arab Emirates
May 12, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the United Arab Emirates (UAE) has requested to buy additional F-16 aircraft components, spares, and accessories; and other related elements of logistics and program support that will be added to a previously implemented case whose value was below the congressional notification threshold. The original Foreign Military Sales (FMS) case, valued at $40.9 million ($0 in MDE), included Common Munitions Built-in-Test Reprogramming Equipment (CMBRE); munitions support equipment; night vision device (NVD) support and spare equipment; spare parts, consumables and accessories; repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; site surveys; studies and surveys; transportation support; U.S. Government and contractor engineering, technical, and logistics support services. The estimated total cost is $130 million. There are no principal contractors associated with this potential sale. 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 Türkiye
May 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Republic of Türkiye has requested to buy sixty (60) AIM-9X Sidewinder Block II All Up Round (AUR) missiles and eleven (11) AIM-9X Block II Tactical guidance units. The following non-MDE items will be included: missile containers and support equipment; spare parts, and missile 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 $79.1 million. The principal contractor will be RTX Corporation, 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 Türkiye
May 14, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Republic of Türkiye has requested to buy fifty-three (53) AIM-120C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM); and six (6) AIM-120C-8 AMRAAM guidance sections. The following non-MDE items will be included: AMRAAM containers and support equipment; Common Munitions Built-in-Test (BIT) Reprogramming Equipment (CMBRE); spare parts, consumables and accessories, repair and return support; weapons system support and software; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $225 million. The principal contractor will be RTX Corporation, 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 Bosnia and Herzegovina
May 20, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that Bosnia and Herzegovina has requested to buy AW-119Kx helicopters; qualification and transition training of pilots and maintainers; in-country contractor field service representative support; program management reviews; technical assistance; product support; associated aviation ground support equipment; platform-peculiar ground support equipment; hardware; special tools; test equipment and basic issue items; quality assurance team inspections; inventories; ground run and flight test validation and verification testing; air freight transportation delivery; initial spares, repair and consumable parts; operator maintenance; and technical manuals; 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 $100 million. The principal contractor will be Leonardo Helicopters U.S., 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 Notifies Congress of Potential FMS Sale To Poland
May 21, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Poland has requested to buy one thousand four hundred (1,400) GBU-39/B Small Diameter Bombs (SDB-I); and four (4) GBU-39 (T-1)/B inert practice bombs with fuzes. The following non-MDE items are also included: GBU-39 tactical training rounds; practice bombs; bomb components; containers; weapons system support; support and test equipment; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical data; personnel training and training equipment; warranties; transportation support; site surveys; 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 $180 million. The principal contractor will be The Boeing Corporation, located in St. Louis, MO. 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 Estonia
May 22, 2025: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that the Government of Estonia has requested to buy eight hundred (800) FGM-148F Javelin missiles (including 8 fly-to-buy missiles) and an additional seventy-two (72) Javelin Lightweight Command Launch Units (LwCLUs) 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 $10.18 million ($3.1 million in MDE), included twelve (12) LwCLUs; LwCLU Basic Skills Trainers; Javelin missile simulation rounds; Battery Coolant Units; spare parts; tool kits and support equipment; equipment training; U.S. Government and contractor technical assistance and services; engineering services; and related elements of logistics and program support. This notification is for a combined eight hundred (800) FGM-148F Javelin missiles (including 8 fly-to-buy missiles) and eighty-four (84) LwCLUs. The following non-MDE items will also be included: LwCLU Basic Skills Trainers; Javelin missile simulation rounds; Battery Coolant Units; spare parts; tool kits and support equipment; equipment training; U.S. Government and contractor technical assistance and services; engineering services; and related elements of logistics and program support. The estimated total program cost is $296 million. The principal contractors will be the Javelin Joint Venture between RTX Corporation, located in Tucson, AZ, 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.
https://www.dsca.mil/Press-Media/Major-Arms-Sales/Article/4195631/estonia-javelin-missiles
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Department of Commerce – Bureau of Industry and Security (BIS)
Department of Commerce Launches Section 232 Steel and Aluminum Inclusions Process
May 1, 2025: On April 30, 2025, the Department of Commerce issued an interim final rule establishing a new tariff inclusion process for derivative aluminum and steel articles.
This action follows the issuance of Presidential Proclamations 10895 and 10896, collectively known as the “Inclusion Proclamations,” which direct the Secretary of Commerce to establish a mechanism for expanding the scope of steel and aluminum tariffs to cover “derivative” articles that contain steel or aluminum.
The Section 232 inclusions process allows U.S. manufacturers and trade associations to request the inclusion of new derivative articles under Section 232 steel and aluminum tariffs. Inclusions may be submitted during any of three defined periods each year. The first submission period opens May 1, 2025. The public will have an opportunity to comment on inclusion requests, and decisions will be issued within 60 days. BIS will publicly post its determinations on Regulations.gov.
Today’s rule also eliminates the Section 232 aluminum and steel exclusions process. In accordance with the Inclusion Proclamations, no new applications for product exclusions have been accepted after February 10,2025.
Jeffrey Kessler, Under Secretary of Commerce for Industry and Security, said:
“The new steel and aluminum inclusions process will extend the reach of the steel and aluminum tariff program and shut down avenues for circumvention – bringing industry and jobs back to the United States.”
Beyond the establishment of the steel and aluminum inclusions process, Commerce is currently conducting six Section 232 investigations in support of the President’s America First Agenda, including inquiries into the national security impact of imports of copper, timber, lumber, semiconductors, pharmaceuticals, critical minerals, and medium- and heavy-duty trucks into the United States. In addition, Commerce recently imposed tariffs on autos and auto parts under Section 232.
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Department of Commerce Rescinds Biden-Era Artificial Intelligence Diffusion Rule, Strengthens Chip-Related Export Controls
May 13, 2025: The Department of Commerce initiated a rescission of the Biden Administration’s AI Diffusion Rule, while announcing additional steps to strengthen export controls on semiconductors worldwide.
The AI Diffusion Rule was issued on January 15, 2025, with compliance requirements that were set to come into effect on May 15, 2025. These new requirements would have stifled American innovation and saddled companies with burdensome new regulatory requirements. The AI Diffusion Rule also would have undermined U.S. diplomatic relations with dozens of countries by downgrading them to second-tier status.
BIS plans to publish a Federal Register notice formalizing the rescission and will issue a replacement rule in the future.
Under Secretary of Commerce for Industry and Security Jeffery Kessler has instructed BIS enforcement officials not to enforce the Biden Administration’s AI Diffusion Rule, stating:
“The Trump Administration will pursue a bold, inclusive strategy to American AI technology with trusted foreign countries around the world, while keeping the technology out of the hands of our adversaries. At the same time, we reject the Biden Administration’s attempt to impose its own ill-conceived and counterproductive AI policies on the American people.”
In addition, BIS announced actions to strengthen export controls for overseas AI chips, including:
- Issuing guidance alerting industry to the risks of using PRC advanced computing ICs, including specific Huawei Ascend chips.
- Issuing guidance warning the public about the potential consequences of allowing U.S. AI chips to be used for training and inference of Chinese AI models.
- Issuing guidance to U.S. companies on how to protect supply chains against diversion tactics.
These actions ensure that the United States will remain at the forefront of AI innovation and maintain global AI dominance.
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Reporting for Calendar Year 2024 on Offsets Agreements Related to Sales of Defense Articles or Defense Services to Foreign Countries or Foreign Firms
May 21, 2025: 90. Fed. Reg. 21738: This notice is to remind the public that U.S. firms are required to report annually to the Department of Commerce (Commerce) information on contracts for the sale of defense articles or defense services to foreign countries or foreign firms that are subject to offsets agreements exceeding $5,000,000 in value. U.S. firms are also required to report annually to Commerce information on offsets transactions completed in performance of existing offsets commitments for which an offsets credit of $250,000 or more has been claimed from the foreign representative. This year, such reports must include relevant information from calendar year 2024 and must be submitted to Commerce no later than June 15, 2025.
U.S. Census Bureau
Update to Automated Export System (AES) Appendix F – Update to C65 and C75 License Type Codes
May 6, 2025:
CSMS # 64956194 - Update to Automated Export System (AES) Appendix F – Update to C65 and C75 License Type Codes
Update to the Automated Export System Trade Interface Requirements – Appendix F has been posted to CBP.gov.
The following license type codes have been updated:
License Code: C65
- Removed 3A991 ECCN
- Added 3B991 ECCN
License Code: C75
- Added 5A002.z
Documentation is available under the ACE AESTIR Appendix F - License and License Exemption Type Codes webpage which can be located at: https://www.cbp.gov/document/guidance/aestir-appendix-f-license-and-license-exemption-type-codes
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Update to AESDirect – Displaying Participating Government Agency (PGA) Records
May 15, 2025:
Note: This update is specific to filers who use AESDirect as their connection method.
AESDirect will be updated on Tuesday, May 20, 2025, to allow all AESDirect participants to see the PGA requirements that have been integrated in AESDirect. Prior to this change, some PGA requirements were based on Pilot participation and were only available to those participants.
When a Schedule B/ HTS number is found on Appendix X, the appropriate PGA record will now be available to all filers in AESDirect based on each agency’s requirements. Shipments subject to PGA data requirements must submit a PGA record in the Automated Export System (AES).
When reporting for PGA data, filers will need to indicate ‘Yes’ in Step 3 to the question: Does this filing require Participating Government agency data? The additional PGA data will then display for you to enter the appropriate data elements.
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How to Resolve Common AES Response Messages
May 19, 2025
Note: This message is sent to all AES Updates subscribers and is for educational purposes only.
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: 136
Narrative: PR to US Requires PR Port of Export
Severity: Fatal
Reason: The Country of Destination is reported as the Unites States and the Port of Export Code is not a Puerto Rican port.
Resolution: A Port of Export Code must be reported on shipments from Puerto Rico to the United States and it must be a Puerto Rican port.
See Appendix D, Export Port Codes for a list of acceptable Port of Export Codes.
Verify the Country of Ultimate Destination and Port of Export Code, correct the shipment and resubmit.
For a complete list of the AES Response Codes, their reasons and resolutions, see Appendix A – Commodity Filing Response Messages.
As a reminder, filers have multiple resources that they can use when filing EEI to the AES. You can access User Guides, Walk-through videos and other resources at our website.
| 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
May 22, 2025: 90 Fed. Reg. 21886: On April 17, 2024, in the U.S. District Court for the Middle District of Florida, Sergey Karpushkin (“Karpushkin”), was convicted of violating 18 U.S.C. 371. Specifically, Karpushkin conspired with others to purchase and receive over $139 million in metal products from companies owned by a sanctioned oligarch. As a result of his conviction, the Court sentenced Karpushkin to 21 months of imprisonment, with credit for time served, and three years of supervised release.
Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 371, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.
BIS received notice of Karpushkin's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Karpushkin to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Karpushkin.
Based upon the Office of Export Enforcement’s review of the record and consultations with BIS' Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Karpushkin's export privileges under the Regulations for a period of 10 years from the date of Karpushkin's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Karpushkin had an interest at the time of his conviction.
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May 22, 2025: 90 Fed. Reg. 21887: On March 1, 2023, in the U.S. District Court for the District of Arizona, Arlando Torres (“Torres”) was convicted of violating 18 U.S.C. 554(a). Specifically, Torres was convicted of smuggling and attempting to smuggle from the United States to Mexico, 1,680 rounds of 5.56mm ammunition, 1,000 rounds of 10mm ammunition, 3,200 rounds of 7.62x39mm ammunition, and 50 rounds of 7.62x25mm ammunition. As a result of his conviction, the Court sentenced Torres to 41 months of imprisonment with credit for time served, and three years of supervised release.
Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 554, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.
BIS received notice of Torres's conviction for violating 18 U.S.C. 554. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Torres to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Torres.
Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, the have decided to deny Torres's export privileges under the Regulations for a period of 10 years from the date of Torres's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Torres had an interest at the time of his conviction.
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May 22, 2025: 90 Fed. Reg. 21889; On May 19, 2023, in the U.S. District Court for the Southern District of Florida, Osmani Valdivia Perez (“Perez”), was convicted of violating 18 U.S.C. 371. Specifically, Perez pled guilty to conspiring with others to export from the United States to Mexico stolen vessel parts, specifically outboard engines. As a result of his conviction, the Court sentenced Perez to 60 months in prison and three years of supervised release.
Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 371, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.
BIS received notice of Perez's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Perez to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Perez.
Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Perez's export privileges under the Regulations for a period of seven (7) years from the date of Perez's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Perez had an interest at the time of his conviction.
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May 22, 2025: 90 Fed. Reg. 21890: On December 19, 2023, in the U.S. District Court for the Western District of Texas, Steve Trevino (“Trevino”) was convicted of violating 18 U.S.C. 554(a) (Smuggling Goods from the United States). Specifically, Trevino was convicted of smuggling firearms from the United States to Mexico. As a result of his conviction, the Court sentenced Trevino to 57 months of imprisonment and three years of supervised release.
Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 554, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.
BIS received notice of Trevino's conviction for violating 18 U.S.C. 554. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Trevino to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Trevino.
Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Trevino's export privileges under the Regulations for a period of 10 years from the date of Trevino's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Trevino had an interest at the time of his conviction.
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May 22, 2025: 90 Fed. Reg. 2188: On May 19, 2023, in the U.S. District Court for the Southern District of Florida, Roberto Marrero-Cisneros (“Marrero-Cisneros”) was convicted of violating 18 U.S.C. 371 (conspiracy to export stolen vessel parts and to smuggle goods from the United States). Specifically, Marrero-Cisneros conspired with others to export from the United States to Mexico boat engines and parts that were stolen, in violation of 18 U.S.C. 553(a)(1), and to export boat engines and parts contrary to law, in violation of 18 U.S.C. 554(a). As a result of his conviction, the Court sentenced Marrero-Cisneros to 60 months of imprisonment and three years of supervised release.
Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 371, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.
BIS received notice of Marrero-Cisneros's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Marrero-Cisneros to make a written submission to BIS. 15 CFR 766.25.[2] BIS has not received a written submission from Marrero-Cisneros.
Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Marrero-Cisneros's export privileges under the Regulations for a period of seven (7) years from the date of Marrero-Cisneros's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Marrero-Cisneros had an interest at the time of his conviction.
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May 22, 2025: 90 Fed. Reg. 21887: On May 23, 2023, in the U.S. District Court for the Southern District of Florida, Carlos Orlando Ledesma (“Ledesma”), was convicted of violating 18 U.S.C. 371 (conspiracy to export stolen vessel parts and to smuggle goods from the United States). Specifically, Ledesma conspired with others to export from the United States to Mexico boat engines and parts that were stolen, in violation of 18 U.S.C. 553(a)(1), and to export boat engines and parts contrary to law, in violation of 18 U.S.C. 554(a). As a result of his conviction, the Court sentenced Ledesma to 36 months of imprisonment and three years of supervised release.
Pursuant to Section 1760(e) of the Export Control Reform Act (“ECRA”), the export privileges of any person who has been convicted of certain offenses, including, but not limited to, 18 U.S.C. 371, may be denied for a period of up to ten (10) years from the date of his/her conviction. 50 U.S.C. 4819(e). In addition, any Bureau of Industry and Security (“BIS”) licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked. Id.
BIS received notice of Ledesma's conviction for violating 18 U.S.C. 371. As provided in Section 766.25 of the Export Administration Regulations (“EAR” or the “Regulations”), BIS provided notice and opportunity for Ledesma to make a written submission to BIS. 15 CFR 766.25. BIS has not received a written submission from Ledesma.
Based upon the Office of Export Enforcement’s review of the record and consultations with BIS's Office of Exporter Services, including its Director, and the facts available to BIS, they have decided to deny Ledesma's export privileges under the Regulations for a period of seven (7) years from the date of Ledesma's conviction. The Office of Exporter Services has also decided to revoke any BIS-issued licenses in which Ledesma had an interest at the time of his conviction.
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Sanctions
Department of the Treasury, Office of Foreign Assets Control (OFAC)
May 1, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three Mexican nationals, and two Mexico-based entities involved in a drug trafficking and fuel theft network linked to the Cartel Jalisco Nueva Generacion (CJNG). This network generates hundreds of millions of dollars annually, benefitting CJNG, through a slew of criminal activities, including fentanyl trafficking, fuel theft, and smuggling stolen crude oil from Mexico across the southwest border. Concurrently, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert that provides financial typologies and red flags indicative of crude oil smuggling schemes on the U.S. southwest border associated with CJNG and other Mexico-based transnational criminal organizations.
The following individuals have been added to OFAC’s SDN List:
- Morfin Morfin, Alvao Noe of Mexico;
- Morfin Morfin, Cesar of Mexico; and
- Morfin Morfin, Remigio of Mexico.
The following entities have been added to OFAC’s SDN List:
- Grupo Jala Logistica, S.A. DE C.V. of Mexico; and
- Servicios Logisticos Ambientales, S.A. DE C.V. of Mexico.
https://ofac.treasury.gov/recent-actions/20250501 and
https://ofac.treasury.gov/media/934256/download?inline=
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May 2, 2025: The United States remains committed to protecting our national security interests and dismantling violent criminal gangs terrorizing the Haitian people.
The Department of State announced the designation of Viv Ansanm and Gran Grif as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs).
- Viv Ansanm is a group formed in September 2023 as a coalition of gangs through an alliance between the two main gang factions operating in Port-au-Prince, G-9 and G-Pép.
- The groups provide a unified platform for criminal groups to use violence to destabilize Haiti and quash actions aimed at restoring state control. Viv Ansanm has launched coordinated attacks on critical infrastructure in Haiti, including prisons, government buildings, and Haiti’s main airport in Port-au-Prince as part of a campaign that, among other things, forced the resignation of former Haitian Prime Minister Ariel Henry.
- Gran Grif is the largest gang in Haiti’s Artibonite department, a region that is home to much of the country’s rice fields. Since 2022, Gran Grif has been responsible for 80 percent of civilian death reports in Artibonite. Gran Grif has attacked Haitian National Police and the UN-authorized Multinational Security Support (MSS) mission, including in the February 2025 attack that killed a Kenyan MSS mission officer.
The following entities have been added to OFAC’s SDN List:
- Gran Grif of Haiti; and
- Viv Ansanm of Haiti.
https://ofac.treasury.gov/recent-actions/20250502 and
https://www.state.gov/designation-of-viv-ansanm-and-gran-grif/
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May 5, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Karen National Army (KNA), a militia group in Burma, as a transnational criminal organization, along with the group’s leader Saw Chit Thu, and his two sons, Saw Htoo Eh Moo and Saw Chit Chit, for their role in facilitating cyber scams that harm U.S. citizens, human trafficking, and cross-border smuggling. The KNA-controlled region, located on the Thai-Burmese border, is home to multiple cyber scam syndicates, and the KNA has benefitted from its connection to Burma’s military in its criminal operations. Although statistics vary, American victims of cyber scams like the ones emanating from Burma have collectively lost billions of dollars over the last three years.
The following individuals have been added to OFAC’s SDN List:
- Chit, Saw Chit of Burma;
- Eh Moo, Saw Htoo of Burma; and
- Thu, Saw Chit of Burma.
The following entity has been added to OFAC’s SDN List:
- Karen National Army of Burma.
https://ofac.treasury.gov/recent-actions/20250505 and
https://home.treasury.gov/news/press-releases/sb0129
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May 8, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) increased pressure on Iran’s export of oil, designating the “teapot” refinery Hebei Xinhai Chemical Group Co., Ltd. and three port terminal operators in Shandong Province for their role in purchasing or facilitating the delivery of hundreds of millions of dollars’ worth of Iranian oil. These teapot refineries, most of which are located in Shandong Province, purchase the majority of Iranian crude oil exports. OFAC also imposed sanctions on several companies, vessels, and captains responsible for facilitating Iranian oil shipments as part of Iran’s “shadow fleet.” This is OFAC’s third action against a teapot refinery and its first targeting terminal operators in Shandong Province.
The following individuals have been added to OFAC’s SDN List:
- Agarwal, Ketan of India; and
- Viegas, Lincoln Francisco of India.
The following entities have been added to OFAC’s SDN List:
- Baogang Dongying Donggang Logistics and Warehousing Co., Ltd. of China;
- Embrace Que Limited of China;
- Hebei Xinhai Chemical Group Co., Ltd. of China;
- Hong Kong Prime Trading Co., Limited of China;
- Nissho Lines Incorporated of the Marshall Islands;
- Propitous Forever Trading Co Ltd of the United Kingdom;
- Shandong Baogang International Port Co., Ltd. of China;
- Shandong Jingang Port Co., Ltd. of China;
- Skadi Limited of the Marshall Islands;
- Star Twinkle Shipping Limited of China; and
- Xing AO Energy Pte. Ltd. of Singapore.
The following vessels have been added to OFAC’s SDN List:
- Big Mag (HORS) Crude Oil Tanker Panama flag; MMSI 356336000 (vessel);
- Impalas (S9Z4) Crude Oil Tanker Sao Tome & Principe flag; MMSI 668116257 (vessel);
- Lamd (a.k.a. TAI HE) (3E6106) Crude Oil Tanker Panama flag; MMSI 352003859 (vessel);
- Skadi (HPPN) Crude Oil Tanker Panama flag; MMSI 352421000 (vessel);
- Star Twinkle 6 (3E5173) Crude Oil Tanker Panama flag; MMSI 352003519 (vessel); and
- Thane (T7BR8) Crude Oil Tanker San Marino flag; MMSI 268246702 (vessel).
https://ofac.treasury.gov/recent-actions/20250508
https://home.treasury.gov/news/press-releases/sb0135
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May 12, 2025: Sayyed Mohammad Reza Seddighi Saber is the head of Iran’s Organization of Defensive Innovation and Research’s (also known by its Persian acronym, SPND) Shahid Karimi Group, a group that works on explosives-related projects. Seddighi Saber is linked to projects including research and testing applicable to the development of nuclear explosive devices.
Ahmad Haghighat Talab is an SPND senior official and a nuclear scientist who was previously involved in Iran’s pre-2004 weapons program: the Amad Project. Talab continues to use his scientific expertise to advance Iran’s nuclear-related research and development efforts that have potential military applications. As an SPND senior official, Talab also coordinates with Iranian researchers who work on nuclear research with dual-use purposes.
Mohammed Reza Mehdipur is a longtime SPND-affiliated official who has been involved in explosion and shock research on behalf of SPND. Mehdipur was appointed as head of SPND’s Shahid Chamran Group, which has conducted nuclear-related research. As a longtime explosives and nuclear researcher, Mehdipur has supported SPND’s nuclear and explosives research and development efforts, including those with potential military applications.
Fuya Pars Prospective Technologists, also known as Ideal Vacuum, is an SPND-affiliated company that has attempted to procure from foreign suppliers, as well as indigenously fabricate, equipment that could be applicable in nuclear weapons research and development.
The Department of State is designating Fuya Pars Prospective Technologists (Ideal Vacuum), Sayyed Mohammad Reza Seddighi Saber, Ahmad Haghighat Talab, and Mohammed Reza Mehdipur for sanctions pursuant to E.O. 13382 for engaging or attempting to engage in activities or transactions that materially contribute to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery (including missiles capable of delivering such weapons), including any efforts to manufacture, acquire, possess, develop, transport or transfer such items, by Iran, a foreign country of proliferation concern.
The following individuals have been added to OFAC’s SDN List:
- Saber, Sayyed Mohammed Reza Seddighi of Iran; and
- Talab, Ahmad Haghighat of Iran.
The following entity has been added to OFAC’s SDN List:
- Fuya Pars Prospective Technologists of Iran.
https://ofac.treasury.gov/recent-actions/20250512
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May 13, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned nearly two dozen firms operating in multiple jurisdictions in virtually every aspect of Iran’s illicit international oil trade. The Iranian government allocates billions of dollars’ worth of oil annually to its armed forces to supplement their budget allocations, underwriting the development of ballistic missiles and unmanned aerial vehicles, as well as financing regional terrorist groups. Iran’s Armed Forces General Staff (AFGS) and its main commercial affiliate, Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), continue to establish front companies and rely on buyers and facilitators to enable their sanctioned oil trade. Since the start of this administration, Treasury has rapidly moved to implement President Trump’s maximum pressure campaign on Iran and have taken 19 actions, sanctioning 253 individuals, entities, and vessels related to Tehran and its proxies.
The following individual has been added to OFAC’s SDN List:
- Khorasani Niasari, Mohammad of Iran.
The following entities have been added to OFAC’s SDN List:
- CCIC Singapore Pte. Ltd. of Singapore;
- Continental Sinoil Group Limited of China;
- Fine Sanmata Shipping Co., Limited of China;
- Forsal Chartering Corporation of Seychelles;
- Huangdao Inspection and Certification Co., Ltd of China;
- Metaone Trading Limited of China;
- Milen Trading Co., Limited of China;
- Nanhai Limited of China;
- Oriental Apple Company Pte Ltd of Singapore;
- Qingdao Fushen Petrochemical Co., Ltd of China;
- Qingdao Linkrich International Shipping Agency Co., Ltd of China;
- South Sea Energy Limited of China;
- Star Energy International Limited of China;
- Winso Trading Limited of China; and
- Xin Rui Ji Trad Co., Limited of China.
The following vessels have been added to OFAC’s SDN List:
- Balu (TJM0133) Floating Storage Tanker Cameroon flag; MMSI 613469620 (vessel); and
- Roc (3E6750) Crude Oil Tanker Panama flag; MMSI 352004455 (vessel).
https://ofac.treasury.gov/recent-actions/20250513
https://home.treasury.gov/news/press-releases/sb0139
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May 14, 2025: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and 12 entities for their involvement in efforts to help the Iranian regime domestically source the manufacturing of critical materials needed for Tehran’s ballistic missile program. Those sanctioned support the various Islamic Revolutionary Guard Corps (IRGC) sub-organizations that oversee the effort to help Iran domestically develop carbon fiber materials needed to manufacture intercontinental ballistic missiles. This action is being taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied intercontinental ballistic missiles and that the IRGC and its surrogates be disrupted, degraded, or denied access to the resources that sustain their destabilizing activities.
The following individuals have been added to OFAC’s SDN List:
- Qin, Dehui of China;
- Qin, Jinhua of China;
- Rezai, Mohammad of Iran;
- Wang, Chao of China; and
- Wang, Piao of China.
The following entities have been added to OFAC’s SDN List:
- Advanced Fiber Development Company of Iran;
- Nantong Tanchen High Performance Material Co Ltd of China;
- Nantong Yihong New Materials Co Ltd of China;
- Qingdao Premier Technology Co Ltd of China;
- Reso Trading Shanghai Co Ltd of China;
- Sarmand Sazeh Sazan Saroush of Iran;
- Shanghai Ninestex New Material Technology Co Ltd of China;
- Shanghai Tanchain New Material Technology Co Ltd of China;
- Sharif Hamrah Science and Technology Researchers of Iran; and
- Super Sources Industrial Co Limited.
https://home.treasury.gov/news/press-releases/sb0142
https://ofac.treasury.gov/recent-actions/20250514
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May 15, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted two senior Hizballah officials and two financial facilitators for their roles in coordinating financial transfers for Hizballah. These individuals, based in Lebanon and Iran, work closely with Hizballah leadership to send money to the group from overseas donors. These donations are a significant portion of the terrorist group’s overall budget. In addition to managing and processing funding for Hizballah within Lebanon, one of these individuals is responsible for overseeing financial activity for Hizballah-aligned groups around the world.
The following individuals have been added to OFAC’s SDN List:
- Alami, Jihad of Lebanon;
- Al-‘Amili, Mu’in Daqiq of Lebanon;
- Nehme, Fadi of Lebanon; and
- Ni’Mah, Hasan Abdallah of Lebanon.
https://ofac.treasury.gov/recent-actions/20250515
https://home.treasury.gov/news/press-releases/sb0143
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May 15, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related General License 124, "Authorizing Petroleum Services Related to the Caspian Pipeline Consortium and Tengizchevroil."
GENERAL LICENSE NO. 124: “Authorizing Petroleum Services Related to the Caspian Pipeline Consortium and Tengizchevroil Projects”
- All transactions prohibited by the determination of January 10, 2025 made pursuant to section 1(a)(ii) of Executive Order 14071 (“Prohibition on Petroleum Services”) that are related to the Caspian Pipeline Consortium or Tengizchevroil projects are authorized.
Additionally, OFAC has published an updated Russia-related Frequently Asked Question (FAQ 1216).
FAQ 1216:
Q: What action has Treasury taken with regard to the provision of petroleum services to Russia?
A: In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services ("the Petroleum Services Determination"). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination took effect at 12:01 a.m. eastern standard time on February 27, 2025. See FAQ 1217 for additional information.
OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia's ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia's domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.
OFAC issued General License 121 to authorize any petroleum services that would otherwise be prohibited by the Petroleum Services Determination related to the operations of the Caspian Pipeline Consortium (CPC), Tengizchevroil, and Sakhalin II. GL 121 expires on June 28, 2025. On May 15, 2025, OFAC issued GL 124, which extends without time limitation authorizations related to the CPC and Tengizchevroil.
The Petroleum Services Determination does not apply to (1) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (2) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (3) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.
https://ofac.treasury.gov/media/934251/download?inline
https://ofac.treasury.gov/faqs/1216
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May 20, 2025: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Iran-related General License Q, "Authorizing Limited Safety, Environmental, and Sale Transactions Involving the Blocked Vessel M.V. Tinos I While Located in the United States."
GENERAL LICENSE Q: “Authorizing Limited Safety, Environmental, and Sale Transactions Involving the Blocked Vessel M.V. Tinos I While Located in the United States”
(a) All transactions prohibited by Executive Order (E.O.) 13902 involving the vessel M.V. Tinos I (IMO: 9969821) (Tinos I), Meisam Emamjomeh, or Pearl Petrochemical FZE, or any entity in which any of the foregoing owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, that are ordinarily incident and necessary to one or more of the following activities are authorized, provided that any payments to a blocked person must be made into a blocked interest-bearing account at a U.S. financial institution:
(1) The safe docking and anchoring of the Tinos I in port;
(2) The preservation of the health and safety of the crew of the Tinos I;
(3) Emergency repairs and environmental mitigation or protection activities related to the Tinos I;
(4) The provision of vessel management, bunkering, pilotage, towing, insurance, classification, flagging, registration, crewing, or port agency services for the Tinos I, as well as other services necessary to maintain normal vessel standards for the Tinos I; or
(5) The sale of the Tinos I provided the net proceeds of the sale be placed into a blocked interest-bearing account at a U.S. financial institution.
Note to paragraph (a)(5). Transactions authorized by paragraph (a)(5) include: bidding on the purchase of the vessel; paying deposits; providing financing, insurance, or funding in connection with the purchase; and, in furtherance of the sale of the vessel, repairing or modifying the vessel for commercial use and hiring surveyors to inspect the vessel.
https://ofac.treasury.gov/media/934291/download?inline
https://ofac.treasury.gov/recent-actions/20250520
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May 21, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two high-ranking members of the Mexico-based Cartel del Noreste (CDN), formerly known as Los Zetas. CDN, one of the most violent drug trafficking organizations in Mexico and a U.S.-designated Foreign Terrorist Organization (FTO), exerts significant influence over the border region, especially near the Laredo/Nuevo Laredo point of entry. These sanctions underscore the commitment to target CDN and other violent cartels involved in drug trafficking, human trafficking, arms trafficking, and other heinous crimes that are endangering the American people.
The following individuals have been added to OFAC’s SDN List:
- De Anda Ledezma, Miguel Angel of Mexico; and
- Gonzalez Sauceda, Ricardo of Mexico.
https://ofac.treasury.gov/recent-actions/20250521
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May 23, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with the President’s announcement for the cessation of all sanctions on Syria. GL 25 authorizes transactions prohibited by the Syrian Sanctions Regulations, effectively lifting sanctions on Syria. GL 25 will enable new investment and private sector activity consistent with the President’s America First strategy. The U.S. Department of State concurrently issued a waiver under the Caesar Syria Civilian Protection Act (Caesar Act) that will enable our foreign partners, allies, and the region to further unlock Syria’s potential. This is just one part of a broader U.S. government effort to remove the full architecture of sanctions imposed on Syria due to the abuses of the Bashar al-Assad regime.
The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Syria General License 25, "Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons."
GENERAL LICENSE NO. 25: “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons”
(a) All transactions prohibited by the Syrian Sanctions Regulations, 31 CFR part 542 (SySR), other than transactions involving blocked persons, are authorized.
(b) All transactions that are prohibited by the SySR, the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 CFR part 544, the Iranian Financial Sanctions Regulations, 31 CFR part 561, the Global Terrorism Sanctions Regulations, 31 CFR part 594, the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597, or Executive Order 13574 involving the following blocked persons are authorized:
(1) the Government of Syria, as defined by 31 CFR § 542.308, as in existence on or after May 13, 2025; (2) any blocked person listed in the Annex to this general license; or
(3) any entity in which one or more of the blocked persons listed in the Annex own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
Note to paragraph (b)(1). The Government of Syria includes Syrian President Ahmed al-Sharaa and his government.
https://ofac.treasury.gov/recent-actions/20250523_33
https://home.treasury.gov/news/press-releases/sb0148
https://ofac.treasury.gov/media/934306/download?inline
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May 29, 2025: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Funnull Technology Inc., a Philippines-based company that provides computer infrastructure for hundreds of thousands of websites involved in virtual currency investment scams, commonly known as “pig butchering,” along with its administrator, Liu Lizhi. Americans lose billions of dollars annually to these cyber scams, with revenues generated from these crimes rising to record levels in 2024. Funnull has directly facilitated several of these schemes, resulting in over $200 million in U.S. victim-reported losses.
The following individual has been added to OFAC’s SDN List:
- Liu, Lizhi of China.
The following entity has been added to OFAC’s SDN List:
- Funnull Technology Inc of China.