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Export Practitioner Sept. 2026

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Recent stories
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.
Justice Department
DOJ Fraud Division Sets Corporate Enforcement Priorities, Directs Whistleblower Incentives
he 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.
California Executive Charged in $300 Million AI Server Export Scheme
A California technology executive was arrested October 1 on charges that he helped smuggle more than $300 million in export-controlled computer servers to China through intermediaries in Malaysia and Singapore.
COMAC C919 Test Flight
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.

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