Trade Compliance Brief - Export Control and Sanctions Insights

On February 24, 2026, China’s Ministry of Commerce (MOFCOM) fundamentally altered the trade landscape by adding 20 Japanese entities to its Export Control List and 20 more to a "Watch List." This episode of the Trade Compliance Brief analyzes why icons like Subaru, Mitsubishi Materials, and TDK are now under intense scrutiny. We discuss the shift toward restricting any dual-use items that "enhance Japan's military capabilities" and what this means for global supply chains relying on Chinese raw materials and components.Link to Mofcom Announcement: https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_bac18400512d408a8d4c2f964e36ac11.html

In this episode of the Trade Compliance Brief, we dissect the February 26, 2026, BIS Final Order against Teledyne FLIR LLC. We explore how 18 violations of the EAR led to a significant civil penalty and learnings from this case. BIS Order can be found here: https://www.bis.gov/press-release/bis-reaches-administrative-enforcement-settlement-teledyne-flir-llc-its-affiliates-flir-optoelectronic

In this episode of the Trade Compliance Brief, we break down the latest OFAC settlement involving a U.S. person residing abroad. We analyze the 20 violations of the Syrian Sanctions Regulations (SySR) that resulted in a $3.77 million penalty.Key topics covered:The definition of a "U.S. Person" and why residency doesn't waive liability.What constitutes "Reckless Disregard" in the eyes of the Treasury.Why the termination of a sanctions program does not provide amnesty for past conduct.Actionable lessons for Global Compliance Programs and risk mitigation.Link to OFAC enforcement release document: https://ofac.treasury.gov/media/935041/download?inline

Did you know that uploading a technical drawing to an offshore supplier portal is legally the exact same as shipping a controlled item across the border?In this episode of The Trade Compliance Brief, we break down the February 2026 Bureau of Industry and Security (BIS) Final Order against Vizocom ICT. What started as a routine procurement effort for military radio antennas turned into a massive Export Administration Regulations (EAR) violation, a deliberate supply chain cover-up, and a $374,474 civil penalty.We dissect the critical mistakes made by Vizocom, starting with uploading 600-series (ECCN 3E611) technical data to a Chinese manufacturing portal. We also explore the fallout of attempting to "origin wash" the resulting components to hide their PRC origins from government customers.What you’ll learn in this episode:The RFQ Trap: Why requests for quote on platforms like "Made in China" are heavily scrutinized exports.The 600-Series Reality: The severe restrictions surrounding military-grade technical data and the PRC.Origin Washing: Why repackaging foreign-made goods to obscure their origin compounds your legal exposure.Actionable Advice: How to align your procurement and purchasing teams with your export control program before they click upload.Resources Mentioned:Read the full BIS Final Order here: https://www.bis.gov/media/documents/vizocom-ict-final-order-2-24-2026.pdfSubscribe & Review: If you found this breakdown helpful, please subscribe to The Trade Compliance Brief and leave us a review! Share this episode with your procurement managers and engineering teams to help safeguard your supply chain.

The Supreme Court has officially struck down the IEEPA tariffs in Learning Resources, Inc. v. Trump, sending shockwaves through the global trade and customs compliance world. But with the administration immediately pivoting to Section 122 of the 1974 Trade Act, the chaos is just beginning. If you as trade compliance expert try to figure out what happens next, this episode is your survival guide. We break down the historic 6-3 SCOTUS decision, the legal limits of emergency executive powers, and the harsh realities of the administration's new temporary 15% global tariff.We cut through the political noise to deliver the hard, actionable facts trade compliance officers and supply chain executives need to know right now.In this episode, we cover:The SCOTUS Ruling Explained: Why the Supreme Court used the Major Questions Doctrine to rule that regulating importation does not equal taxing.The Section 122 Pivot: How the administration is using the 1974 Trade Act as a loophole, and why the ticking 150-day clock matters to your bottom line.The $133 Billion Refund Nightmare: Will U.S. importers actually get their illegally collected IEEPA tariffs back? We discuss the logistical mess and what you need to do to preserve your CBP protest claims.Global Supply Chain Fallout: The EU’s threat to suspend the Turnberry agreement, impending retaliatory levies, and how to adjust your scenario planning. Whether you are managing risk, auditing customs entries, or bracing for international retaliation, this is a must-listen breakdown of the biggest trade compliance story of the year.Subscribe & Review: If this episode helped you navigate the tariff chaos, please subscribe on Apple Podcasts or Spotify and leave us a review! It helps other trade professionals find the show.

In this episode of The Trade Compliance Brief, we dissect the recent filing of Case T-693/25, Tokareva v. Council, at the General Court of the European Union. We analyze the applicant’s grounds for the annulment of restrictive measures and what this litigation means for the future of EU sanctions enforcement. If your firm manages frozen assets or denied party screening, this deep dive into the legal challenges of Council decisions is essential listening.Judgement: https://infocuria.curia.europa.eu/tabs/document/T/2025/T-0693-25-00000000RD-01-P-01/ARRET_NP/315477-FR-1-html

When Elite Sports Meets International Sanctions.In this episode, we break down a shocking enforcement action from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). IMG Academy, the world-renowned athletic training facility in Bradenton, Florida, has agreed to a $1,720,000 settlement for apparent violations of counternarcotics sanctions.What happened? Between 2018 and 2022, IMG Academy entered into yearly tuition contracts with two individuals—referred to as SDN 1 and SDN 2—who were sanctioned for their ties to a Mexican drug cartel. Despite the individuals using their real names, which matched the OFAC SDN List, the school failed to conduct basic sanctions screening.Inside this episode:The Details: How the academy processed 89 transactions totaling over $1.7 million for the children of sanctioned "Kingpins".The "Reckless Disregard": Why OFAC determined that minimal due diligence could have prevented these violations.The Pivot: How a change in ownership and a new Chief Legal Officer in 2023 led to a total compliance overhaul.The Warning: Why academic institutions and "domestic" businesses are now in the crosshairs of global sanctions enforcement.Whether you are a compliance officer, a sports fan, or a business leader, this case is a massive wake-up call that "knowing your customer" is no longer optional.Original Source: https://ofac.treasury.gov/media/935006/download?inline

In this episode of the Trade Compliance Brief, we break down the massive $252.5 million administrative penalty issued by the Bureau of Industry and Security (BIS) against semiconductor giant Applied Materials (AMAT).We dissect the failed "dual-build" strategy, where AMAT shifted the assembly of ion implanter equipment from Gloucester, Massachusetts, to South Korea in an attempt to continue selling to SMIC after it was placed on the Entity List.Key takeaways include:The Compliance Trap: Why AMAT’s reliance on "substantial transformation" was legally incorrect and how it differs from U.S.-origin rules under the EAR.The "Is-Informed" Letter: How the company proceeded with shipments despite receiving direct warning of military end-use risks.Strategic Failure: The internal pressure to prioritize revenue over regulatory constraints, resulting in 56 violations.Tune in to understand why moving final assembly abroad doesn't always change an item's origin—and how to avoid a nine-figure fine.Original Documents: https://www.bis.gov/media/documents/2026.02.11-amat-settlement-documents-combined.pdf

This episode explores critical shifts in German foreign trade law (AWG/AWV) taking effect in on 05.02.2026. https://www.recht.bund.de/bgbl/1/2026/27/VO.html (german only)

Dive into the General Court’s January 2026 ruling against Euro Asia Cargo, a Sri Lankan logistics firm sanctioned for moving critical Kometa antenna modules found in Russian Geran-2 UAVs.In this episode, we unpack:• The "Kometa Connection": How European antennas ended up in Russian drones via a Sri Lankan transshipment hub.• "Indirect Support": Why the Court ruled that transporting war-critical tech constitutes support for Russia's military complex—even if the shipper claims ignorance.• No Excuses: The rejection of the "freedom to conduct business" defense in the face of international security risks. (powered by AI)EU Ruling: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62024TJ0232

This podcast takes you inside the 2026 Critical Minerals Ministerial in Washington, D.C., where Vice President JD Vance and Secretary of State Marco Rubio unveiled a radical shift in U.S. industrial policy. We explore the administration's "Ironclad" strategy to secure the oil and minerals necessary to power the digital economy, moving beyond "book reports" to direct government equity in mining. Episodes detail the launch of Project Vault, a historic $10 billion domestic strategic reserve, and FORGE, the new global alliance designed to decouple supply chains from adversarial control. We also analyze the controversial proposal for a "preferential trade zone" that uses enforceable price floors to protect allied miners from foreign dumping. (powered by AI) Links to documents: https://www.state.gov/releases/office-of-the-spokesperson/2026/02/2026-critical-minerals-ministerial/https://www.state.gov/releases/office-of-the-spokesperson/2026/02/opening-remarks-of-the-critical-minerals-ministerial/

How do European microchips end up in Russian missiles and cyber-surveillance tools reach repressive regimes? In this episode, we break down the January 2026 study "EU trade in dual-use items with conflict-affected regions", authored by Dr. Ian J. Stewart for the European Parliament's Committee on International Trade (INTA),. We explore the gap between the EU’s legal framework (Regulation 2021/821) and the reality of exports to countries like Russia, Israel, and the UAE.Discussion points include:• The "Catch-All" Problem: Why non-listed items (like common electronics) are fueling war machines and evading controls.• Real-World Cases: From the complex corporate network behind Predator spyware to the transit of tapered roller bearings destined for the Israeli defense industry.• Data Black Holes: Why a lack of transparent reporting from Member States makes it nearly impossible to track sanctions evasion and compliance with International Humanitarian Law. (Powered by AI)

With the passage of H.R. 2683, the era of unregulated remote access to U.S. technology is ending. We break down the amendments to the Export Control Reform Act of 2018 (ECRA), which now define "remote access" as a controlled activity alongside traditional exports. Listen in to understand the new licensing requirements for cloud infrastructure providers, the definition of "negligent" access and due diligence challenges for businesses. (powered by AI)

Dive into the 2026 National Defense Strategy (NDS) issued by President Trump and Secretary of War Pete Hegseth. This episode analyzes the administration's shift from "utopian idealism" to "hardnosed realism," focusing on the return of Peace Through Strength and the transition to the Department of War. (powered by AI)

This episode breaks down the $1,500,000 civil penalty assessed against Exyte Management GmbH for 13 violations involving the unauthorized in-country transfer of items subject to the EAR to SMIC Beijing. We examine how Exyte China facilitated the delivery of approximately 884 EAR99 items—including flowmeters and pressure transmitters—through local distributors, failing to realize that U.S. license requirements apply even to transactions that never leave China. Finally, we discuss why robust screening of local-to-local supply chains is critical and how Exyte’s voluntary self-disclosure and compliance improvements ultimately shaped this settlement.

Our latest edition of our Trade Compliance Podcast will cover DOJs massive signal to the trade community. In this episode, we break down the MGI International case—the first major resolution from the DOJ’s Trade Fraud Task Force. We analyze how a $6.8M plastic resin fraud scheme resulted in a corporate declination but criminal charges for a COO, and what this "carrot and stick" approach means for your 2026 compliance strategy. (Powered by AI)

This episode details the $421,234 settlement paid by Swiss Automation, Inc. to resolve allegations that it failed to provide required cybersecurity protections for U.S. Army technical drawings. We explore how a whistleblower lawsuit uncovered these contractual lapses and the resulting financial restitution required by the Department of Justice.To understand the impact, think of it like a security guard leaving the vault door unlocked; even if nothing is stolen, the failure to follow the required protocol is a breach of contract that the government refuses to overlook. (powered by AI)

In this episode, we analyze the 2025 National Security Strategy’s aggressive pivot toward "commercial diplomacy" and the weaponization of the American economy. We unpack the document's explicit demand that allies "align their export controls with ours" as a prerequisite for favorable defense and technology cooperation. We also explore how the strategy reframes traditional sanctions into a broader system of "economic leverage" and "strategic tariffs," designed to force burden-sharing and "surgically extinguish" regional conflicts. Finally, we discuss the "Trump Corollary" to the Monroe Doctrine and how the U.S. plans to use financial tools to induce nations to reject adversarial foreign assistance. (Powered by AI)

In this episode, we break down the December 2025 enforcement action against IPI Partners, LLC, which resulted in an $11.4 million settlement with OFAC. We analyze how a private equity firm violated Ukraine-/Russia-related sanctions by soliciting investments from Russian oligarch Suleiman Kerimov through opaque legal structures. (Powered by AI)

In this episode we will briefly discuss OFAC enforcement case with a $4,677,552 penalty on a U.S. individual (U.S. Person) and King Holdings LLC for willfully dealing in blocked U.S. residential real property owned by a designated Russian oligarch's family member. (Powered by AI)