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Treasury Targets Russian Shadow-Banking Network

The 1,000 Ruble banknotes no longer features V.I. Lenin, rather the monument to Prince Yaroslav the Wise

The Treasury Department has sanctioned the Russia-linked A7 Network as a significant transnational criminal organization while FinCEN is proposing to bar U.S. financial institutions from transmitting funds involving A7's overseas sub-agents, escalating a U.S.-UK effort against an alternative payment system built to keep Russian foreign trade moving under Western sanctions.

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Export Practitioner Sept. 2026

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G7 Reserve Deal Defuses U.S. Diesel Export Threat

President Donald Trump stepped back from threatening a U.S. diesel export ban Friday after the Group of Seven agreed to release 100 million barrels of crude oil and fuel from emergency reserves. The agreement reduces the immediate risk of a supply disruption for Europe and Mexico, while shifting attention to whether reserve releases can bring sustained relief to American consumers.

Treasury Sanctions A7 Shadow-Banking Network

The Treasury Department has sanctioned the Russia-linked A7 Network as a significant transnational criminal organization while FinCEN has moved separately to bar U.S. financial institutions from transmitting funds involving A7's overseas sub-agents, targeting a payment network built to keep Russian foreign trade moving under Western sanctions.

Promises Kept?

U.S. trading partners have begun advancing investments pledged in exchange for tariff relief, but full delivery remains unverified. Japan has identified major projects, while South Korea has selected a Texas power plant and continues to assess nuclear and Alaska LNG proposals.

OFAC Centralizes Sanctions Penalty Rules

The Treasury Department’s Office of Foreign Assets Control has consolidated penalty and enforcement provisions for sanctions imposed under the International Emergency Economic Powers Act and the United Nations Participation Act in new 31 C.F.R. Part 505.

U.S.–Ukraine Fund Approves Energy and Critical Minerals Investments

The approvals mark URIF’s expansion from its first technology investment into energy infrastructure and critical minerals, advancing a U.S.–Ukrainian strategy to pair reconstruction with supply chain security. For project sponsors and investors, the fund offers a channel to seek financing and partnerships in priority sectors, supported by joint government oversight and a developing political risk insurance framework.

DOJ Fraud Division Sets Corporate Enforcement Priorities, Directs Whistleblower Incentives

The memorandum sets investigation priorities for the DOJ’s Fraud Division and identifies factors prosecutors must weigh heavily in corporate charging decisions and negotiated resolutions, including management involvement, harm to taxpayer-funded programs, national security threats and immigration offenses. It also directs new whistleblower incentives, pairing targeted enforcement with efforts to encourage disclosures from companies and individuals, including participants in the misconduct.

Treasury Targets Iran’s Automotive and Rail Industries

Treasury issued determinations under Executive Order 13902 on October 1 targeting Iran’s automotive and rail sectors, alongside designations of industrial firms and foreign suppliers.

Graham Act in place as U.S. and EU Adjust Pressure on Russians

The Graham Act creates immediate compliance risks beyond companies that trade directly with Russia by authorizing tariffs on all goods from major buyers of Russian energy, codifying much of the existing U.S. sanctions regime, and increasing secondary-sanctions exposure for foreign financial institutions. Treasury’s additional Iran-related designation of VTB Bank compounds that banking risk, while the EU’s removal of Alisher Usmanov and Mikhail Fridman—and their continued designation under Latvian and Estonian national sanctions—underscores the need for jurisdiction-specific screening.

OFAC’s new Sanctions Penalties Regulations

OFAC’s new Sanctions Penalties Regulations, effective September 25, 2026, consolidate the enforcement procedures and penalty provisions for IEEPA- and UNPA-based sanctions programs in 31 C.F.R. Part 505. Although OFAC describes the rule as non-substantive, it has immediate compliance consequences: entity settlements and civil penalties must be disclosed publicly at least monthly; respondents have 30 days to contest a Pre-Penalty Notice or initial Finding of Violation; and criminal violations now carry an express willfulness standard, while civil liability remains strict.

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.

U.S. Eases Syria Defense Trade Restrictions; BIS Country-Group Not Yet

The United States has lifted comprehensive economic sanctions on Syria and is easing defense trade restrictions, but export controls remain uneven across agencies. State’s ITAR amendment does not remove Syria from BIS Country Group E:1 or eliminate Syria-specific EAR licensing requirements. Until Commerce acts, businesses must continue to apply those controls alongside targeted Treasury sanctions.

State Corrects ITAR Rule to Restore University Exemption Conditions and U.S. Government Transfer Exceptions

The State Department has filed correcting amendments to restore provisions inadvertently removed by its September 18 amendments to the International Traffic in Arms Regulations (ITAR). The corrections restore three conditions governing universities’ releases of technical data to foreign employees and two exceptions to restrictions on exemption use involving proscribed destinations.

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Licensing

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.

State Revises ITAR Country Policies, Narrows Underwater-Vehicle Controls

The Department of State has issued two ITAR rules scheduled for Federal Register publication on September 18: a final rule revising denial policies and related provisions, and an interim final rule narrowing controls on certain uncrewed underwater vehicles.

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.”

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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.