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US Sanctions ICC, exempts certain services and technology

International Criminal Court, The Hague, Netherlands

The licenses avert an immediate operational shutdown but leave the ICC under sustained U.S. leverage. Routine subscriptions, telecommunications and enterprise software may continue—some indefinitely, others only through April 7, 2027—but vendors must still screen separately sanctioned officials and may withdraw services voluntarily.

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Export Practitioner Sept. 2026

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Amidi penalty puts outbound-investment reporting in focus

Treasury’s first outbound-investment penalty shows that a missed filing can carry substantial consequences even when the government has not alleged that the underlying investment was prohibited.

Green Card Crackdown May Increase Offshore Export-Control Risk

The Trump administration’s suspension of Microsoft, Adobe and six major IT-services companies from the federal permanent labor certification program could produce an unintended trade-compliance consequence: greater reliance on personnel working outside the United States and more cross-border transfers of controlled technology.

American Express Bank Fined $350 Million for AML Failures in Trade-Based Activity

The case illustrates how an AML program can fail when its risk assessment does not reflect its core business. Regulators found that American Express gave insufficient attention to its dominant credit and charge card operations, allowing weaknesses in customer due diligence, transaction monitoring and reporting to persist for years.

Trade Court Seeks New Briefs in Section 301 Forced-Labor Case

A three-judge panel at the Court of International Trade has asked for additional briefing in the lead challenge to USTR’s Section 301 forced-labor duties, narrowing the dispute into threshold and merits questions that could determine both whether the action survives and how broadly any relief would apply.

Senators call for action on Russia Sanctions

The bipartisan appeal puts pressure on the administration to translate the new sanctions law into enforcement before most provisions take effect Oct.

Treasury’s first outbound-investment penalty exceeds value of underlying investment

The case shows that even a small investment through an overseas subsidiary can expose a U.S. parent to substantial penalties. Treasury fined Amidi more than twice the underlying investment’s value for a missed notification, underscoring the need for investors and counsel to identify covered transactions across foreign funds and subsidiaries, document their diligence and meet filing deadlines—even when an investment is permitted.

OFAC Warns Foreign Banks of Iran Sanctions Without Advance Notice

The U.S. Treasury Department’s Office of Foreign Assets Control warned foreign financial institutions on October 5 that continued dealings with Iran or its financial sector could expose them to sanctions under Operation Economic Outcast. The alert states that institutions transacting with sanctioned Iranian financial institutions could be targeted “at any time without advance notification” and urges them to terminate those activities and relationships.

OFAC removes 125 parties; foreign sanctions remain for former Venezuelan and Belarusian officials

Included in the "modernization initiative," OFAC dropped sanctions on former Belarusian transport minister Aliaksei Mikalaevich Auramenka , designated in August 2021 for the forced diversion of Ryanair flight FR4978 and the resulting arrests. The update also removed the designations of three Venezuelans sanctioned for corruption, obstruction of humanitarian aid and undermining democracy.

Aircraft-Part Licensing Slowed for China

Commerce is reportedly delaying aircraft-parts licensing for China, using access to U.S. aviation supplies as leverage in trade negotiations. Slower approvals and limits on quantities licensed raise delivery risks in a market that bought $15.9 billion in U.S. civilian aircraft, engines, equipment and parts in 2025.

BIS Penalties Rise Toward Statutory Maximums Even as Enforcement Volume Falls

A growing share of Bureau of Industry and Security export-control settlements under the Trump administration have approached the maximum penalties allowed by law, according to a Center for Strategic and International Studies analysis published September 24. The findings sharpen a review of BIS enforcement, which found that BIS has completed fewer administrative enforcement matters, as a small number of large settlements have driven aggregate penalties sharply higher.

Busan Extension Signals Possible Further Delay for BIS Affiliates Rule

The reported extension of the U.S.–China Busan trade agreement until January 10, 2027, could prolong the suspension of the Bureau of Industry and Security’s Affiliates Rule. Whether the extension covers that rule, however, remains unconfirmed in the official materials reviewed.

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Licensing

State Proposes Broader ITAR Revisions Following Country-Policy Changes, Underwater-Vehicle Rule, and Corrections

The State Department’s Directorate of Defense Trade Controls has proposed revisions to the U.S. Munitions List, key ITAR definitions, and licensing exemptions. The proposal follows September actions revising country policies, narrowing controls on uncrewed underwater vehicles, and correcting inadvertent deletions from exemption provisions.

State Proposes USML Reductions, “Specially Designed” Changes, and New Repair Exemption

The State Department’s Directorate of Defense Trade Controls is scheduled to publish a proposed rule on October 1 that would narrow U.S. Munitions List controls, revise key ITAR definitions, and establish a license exemption for temporary exports of foreign defense articles for servicing and repair.

Lost Package Exposes Control Risk in MRO Chain

The reported transfer of F-35 components into Chinese custody exposes a control risk in global maintenance, repair, and overhaul networks: sensitive technology remains vulnerable while moving between authorized facilities.

Import regulation and export controls: "two sides of the same coin"

In the waning days of Summer, we sat down with Nazak Nikakhtar, former Commerce Department official and current Chair of Wiley Rein's National Security Practice to hear her thoughts on ECRA, the Entity List, BIS-ITA interplay, and navigating a career in private practice and public service.

People

Andrea Gacki Leaves Record of Pragmatic Enforcement

Andrea Gacki is closing a 25-year career in federal service with an enforcement action that neatly captures her approach: exacting about failures, skeptical of paper compliance and focused on whether financial controls work in practice.

BIS Nominee: Export Controls Must Balance Security and Economics

Abby Warren, President Donald Trump’s nominee to lead export administration at the Commerce Department’s Bureau of Industry and Security, told the Senate Banking Committee July 23 that export controls should address significant national-security risks while accounting for their economic impact

Practitioner Profile: Tim O'Toole

The always cool and ever-original Tim O’Toole, practice lead for Miller & Chevalier Chartered’s export controls and sanctions team, indefatigable compliance educator and host of the Embargoed! Podcast took some time ahead of Independence Day to talk enforcement trends.

Erich Ferrari: 'Sanctions are simple, but they're not easy.'

For businesses and individuals who find themselves on the Office of Foreign Assets Control’s Specially Designated Nationals list, a few firms stand out that offer hope for redemption. Ferrari & Associates is one of them. With 17 years of experience advising clients on how to get off OFAC’s list or avoid sanctions in the first place, founder Erich Ferrari has racked up wins, bringing more than a few blacklisted entities back to life from the designation known as “civil death.”

Read about more people in the news...

Practitioner Profile: Mario Mancuso

Before the semiconductor tensions of the 2020s and the export control reforms of the 2010s, Mario Mancuso led the Bureau of Industry and Security in the final years of the Bush administration — pushing the agency toward greater prominence and deeper national security impact.

Practitioner Profile: Sarah Gerdes

West Coast attorney Sarah Gerdes joined Akin’s international trade practice in Los Angeles at the start of the year as part of its national security & global investigations team after a distinguished tenure in the U.S. Attorney’s Office for the Central District of California, where she most recently served as the Deputy Chief of the National Security Division and Assistant U.S. Attorney. In conversation with The Export Practitioner, edited for length and clarity below, she shared lessons from her experience leading national security investigations and advice for meeting the current moment in enforcement.

Q&A with Ryan Fayhee

Ryan Fayhee, now a partner at Akin Gump, led the issue with his contribution on extradition in export enforcement cases. The piece urged prosecutors to emphasize the deception rogue exporters and middlemen undertake to thwart U.S. national security restrictions in order to sway foreign counterparts, as well as the proper interpretation of dual-criminality treaties. The article was published near the end of Fayhee’s illustrious 11-year run at the U.S. Department of Justice, where he cut his teeth on cross-border investigations covering espionage, sanctions and embargoes, arms proliferation, trade secret theft, cybercrime, corruption, and money laundering. He capped his tenure in the department’s National Security Division as the government’s principal attorney for sanctions and export control prosecutions. Fayhee granted The Export Practitioner an interview, edited for length and clarity below, to discuss how international collaboration in export controls has evolved, how investigations look from the private sector and his ongoing work to bring people back to the U.S.