Export Archives - Customs & International Trade Law Firm

OFAC Extends Cuba Sector Sanctions Risk to Electronics, Manufacturing, Marine, and Technology
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OFAC Extends Cuba Sector Sanctions Risk to Electronics, Manufacturing, Marine, and Technology
Cuba, International Trade, U.S. Office of Foreign Assets Control (OFAC)

OFAC Extends Cuba Sector Sanctions Risk to Electronics, Manufacturing, Marine, and Technology

On November 5, 2026, the Office of Foreign Assets Control (OFAC) determined that the sector-based sanctions authority in Executive Order (E.O.) 14404 applies to the electronics, manufacturing, marine, and technology sectors of the Cuban economy. Any foreign person that the State Department or Treasury determines operates, or has operated, in those sectors is now exposed to blocking sanctions. U.S. importers, exporters, carriers, and logistics providers are affected through their foreign suppliers, vessel operators, and customers, which is where screening and contract reviews should start.

KEY TAKEAWAYS

Effective November 5, 2026, OFAC determined that the sector-based sanctions authority in Section 2(a)(i)(A) of E.O. 14404 applies to the electronics, manufacturing, marine, and technology sectors of the Cuban economy.
These four sectors join the five named in the Executive Order itself: energy, defense and related materiel, metals and mining, financial services, and security.
Operating in a listed sector does not trigger sanctions automatically. Sanctions attach only when the State Department or Treasury makes a determination about a specific foreign person (OFAC FAQ 1256).
The same day, the State Department designated Cuban and third-country companies, individuals, and tanker vessels under E.O. 14404, including two Chinese electronics companies.
Importers, exporters, carriers, and logistics providers should […]

By Jennifer Diaz|2026-11-10T12:16:05-05:00November 10, 2026|Cuba, International Trade, U.S. Office of Foreign Assets Control (OFAC)|0 Comments

OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough
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OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough
U.S. Office of Foreign Assets Control (OFAC)

OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough

On October 27, 2026, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $1,529,685 settlement with Extreme Networks, Inc. for nine apparent violations of the Ukraine-/Russia-Related Sanctions Regulations. The customer was a Russian missile and air defense manufacturer that was not on the SDN List when the transaction closed, but was deemed a blocked person by OFAC at all times by virtue of its majority owner being a a designated entity. Exporters, acquirers, and any company selling through foreign distributors in high-risk markets should test whether their screening looks past the name on the order.

KEY TAKEAWAYS

OFAC treated a Russian defense manufacturer as a blocked person at all relevant times because a designated Russian state-owned company held majority ownership, even though the manufacturer itself was not added to the SDN List until June 2022, after the conduct ended.
According to OFAC, Extreme Networks’ U.S.-led compliance function reviewed the 2018 purchase agreement that named the manufacturer as an end user, and screened all nine later purchase orders, without identifying the blocked party.
OFAC determined the nine apparent violations were egregious and voluntarily self-disclosed. The settlement is $1,529,685, against a base penalty of $1,699,650.
OFAC’s compliance guidance in this case centers on three areas: sanctions diligence in acquisitions (including asset purchases), […]

By Jennifer Diaz|2026-10-29T12:52:53-04:00October 29, 2026|U.S. Office of Foreign Assets Control (OFAC)|0 Comments

U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases
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U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases
U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)

U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases

The U.S. government continues to demonstrate its commitment to enforcing sanctions and export control laws, with three recent announcements from the Department of Justice (DOJ) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) highlighting the risks businesses and individuals face when compliance obligations are overlooked.

Between October 9 and October 14, 2026, federal authorities announced a five-year prison sentence involving North Korean sanctions violations, a settlement with an international freight forwarding company, and an $11.6 million settlement with one of the nation’s largest banks.

Although the cases involve different industries and circumstances, they reinforce a common message: sanctions enforcement extends across the global supply chain.

DOJ: Five-Year Prison Sentence for North Korean Sanctions Violations

On October 14, 2026, DOJ announced that Sasa Micev, a Bosnian national and international arms dealer, was sentenced to 60 months in federal prison after pleading guilty to violations of the International Emergency Economic Powers Act (IEEPA) and North Korean Sanctions Regulations.

According to DOJ, Micev conspired with others to broker the purchase of North Korean SA-18 Igla portable surface-to-air missiles without the required authorization from OFAC. The scheme involved discussions about pricing, efforts to obtain the weapons using falsified documentation, and a meeting in Turkey to complete the transaction. The proposed sale ultimately fell through following a pricing dispute.

OFAC: Freight Forwarder Agrees to $175,015 Settlement

On October 9, 2026, OFAC announced a $175,015 settlement […]

By Jennifer Diaz|2026-10-15T17:10:37-04:00October 15, 2026|U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)|0 Comments

Commerce Defines “U.S. Content” for USMCA Steel and Aluminum Articles Under Proclamation 11032
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Commerce Defines “U.S. Content” for USMCA Steel and Aluminum Articles Under Proclamation 11032
U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP)

Commerce Defines “U.S. Content” for USMCA Steel and Aluminum Articles Under Proclamation 11032

On October 14, 2026, the Bureau of Industry and Security (BIS) published a Federal Register notice defining “U.S. content” for products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA), for purposes of the Section 232 duties under clause (2)(d) of Proclamation 11032. The guidance is effective for products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on October 14, 2026. Importers of Canadian and Mexican aluminum and steel articles listed in Annex I-C to the Proclamation, and the customs brokers and filers who prepare their entries, should review how they value U.S. content before their next entry.

Key Takeaways

BIS defines U.S. content in two parts: (1) the value attributable to parts wholly obtained, entirely produced, or substantially transformed in the United States; and (2) to the extent not otherwise accounted for in part (1), the value attributable to steel melted and poured, aluminum smelted and cast, and/or copper smelted and cast in the United States.
The guidance applies to entries on or after 12:01 a.m. Eastern Time on October 14, 2026.
Under clause (2)(d), the 25 percent duty applies only to the non-U.S. content of USMCA-qualifying Annex I-C articles of Canada and Mexico, and the total effective duty may not be […]

By Jennifer Diaz|2026-10-15T17:04:23-04:00October 15, 2026|U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP)|0 Comments

BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations
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BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations
EAR, Enforcement, Export, penalty, U.S. Bureau of Industry and Security (BIS), Uncategorized

BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations

On October 2, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $2 million administrative settlement with Massachusetts-based Lambda Research Corporation involving 66 alleged violations of the Export Administration Regulations (EAR). The case involved exports of optical and illumination design software, automatic software updates, and transactions with parties on the Entity List and Unverified List.

Key Takeaways

EAR99 does not mean unrestricted. Even software classified as EAR99 may require an export license when the recipient is on the BIS Entity List.
Automatic software updates can constitute exports. BIS charged Lambda with violations involving software updates transmitted to restricted parties after their addition to the Entity List.
Restricted-party screening must be ongoing. A customer who was not restricted when a transaction began may become subject to licensing requirements later.
Distributors do not eliminate export compliance obligations. Exporters must evaluate the actual end users of their products, including transactions conducted through intermediaries.
The Unverified List creates additional compliance requirements. Certain transactions involving Unverified List parties require a UVL statement even when an export license is not otherwise required.
Informal compliance efforts are insufficient. BIS cited Lambda’s lack of written export compliance procedures, employee training, and designated compliance personnel.
Voluntary self-disclosure does not eliminate penalties. […]

By Jennifer Diaz|2026-10-09T11:35:03-04:00October 9, 2026|EAR, Enforcement, Export, penalty, U.S. Bureau of Industry and Security (BIS), Uncategorized|0 Comments

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