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 with Pegasus Worldwide Logistics, a freight forwarding company, to resolve potential civil liability involving four apparent violations of the Illicit Drug Trafficking Sanctions Regulations and six apparent violations of OFAC’s Reporting, Procedures and Penalties Regulations. 

According to OFAC, Pegasus facilitated the importation of a machine supplied by a sanctioned company between September 2023 and February 2024, resulting in dealings involving blocked property. The company also failed to respond fully to an OFAC subpoena for six months. 

OFAC classified the apparent violations as non-egregious and determined that they had not been voluntarily self-disclosed. 

OFAC: Bank of America Reaches $11.6 Million Sanctions Settlement 

On October 13, 2026, OFAC announced an $11,662,930 settlement with Bank of America, N.A., resolving potential civil liability for 475 apparent violations of multiple U.S. sanctions programs, including those targeting Russia, Belarus, Iran, Burma, Somalia, narcotics trafficking, and global terrorism. 

According to OFAC, the apparent violations involved payments processed through blocked banks, failures to appropriately prioritize sanctions screening alerts, delays in updating watchlists following new designations, and human errors involving accounts associated with blocked individuals. 

OFAC determined that the apparent violations were non-egregious but largely not voluntarily self-disclosed. 

What These Enforcement Actions Mean for Businesses 

Taken together, these cases offer several important lessons for companies engaged in international trade and cross-border transactions. 

  1. Sanctions compliance extends beyond importers and exporters.

Freight forwarders, financial institutions, intermediaries, and other service providers can face liability for their roles in prohibited transactions. Businesses should understand their own compliance obligations rather than assuming another party in the transaction is responsible. 

  1. Screening systems are only as effective as the processes behind them.

The Bank of America settlement demonstrates that having sanctions screening technology is not enough. Companies must ensure alerts are appropriately reviewed, sanctions lists are updated promptly, and potential matches are escalated and resolved. 

  1. Cooperation with regulators matters.

The Pegasus settlement underscores the importance of responding fully and promptly to OFAC inquiries. Businesses should establish procedures for handling subpoenas, information requests, and other regulatory communications. 

  1. Sanctions violations can result in both civil and criminal consequences.

While the OFAC matters resulted in civil settlements, the DOJ case resulted in imprisonment. The nature of the conduct, applicable laws, and facts of each case can significantly affect the consequences. 

  1. Compliance programs must evolve with enforcement risks.

Companies should regularly evaluate their sanctions exposure, particularly when dealing with international suppliers, intermediaries, financial institutions, or transactions involving higher-risk jurisdictions and counterparties. 

Contact Diaz Trade Law For Assistance with Export Compliance 

These recent enforcement announcements serve as another reminder that U.S. authorities continue to pursue sanctions violations across industries and transaction types. 

For businesses engaged in international trade, a proactive compliance strategy should include risk-based due diligence, effective restricted-party screening, internal training, documented procedures, and a clear process for identifying and addressing potential violations. 

At Diaz Trade Law, our team assists businesses with sanctions and export control compliance, risk assessments, government inquiries, and enforcement matters. Contact us to discuss how your company can strengthen its compliance program and reduce its exposure. 305-456-3830, info@diaztradelaw.com. 

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