Author: Alex Cotoia

General

1 Oct, 2025

BIS Expands Entity List Controls to Cover Affiliates of Listed Parties

On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List restrictions to cover affiliates of listed parties. Effective on the date of filing for public inspection, the IFR abandons the longstanding “legally distinct” standard, under which only entities expressly enumerated on the Entity...

General

23 Sep, 2025

OFAC Penalizes ShapeShift AG $750,000 for Apparent Sanctions Violations

On September 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the resolution of an enforcement action against ShapeShift AG (“ShapeShift”), a now defunct digital asset exchange incorporated in Switzerland but headquartered and operated from Denver, Colorado. ShapeShift agreed to remit $750,000 to settle its potential civil liability for apparent violations of multiple U.S. sanctions programs, including those directed...

General

22 Sep, 2025

EU Clarifies Ownership and Control Standards in New Sanctions Guidance

The European Union has continued to refine its approach to sanctions compliance by publishing new guidance on the critical issues of “ownership” and “control” through its Sanctions Helpdesk platform. The guidance—released in late August 2025—offers much-needed clarity on how companies operating within the Union should identify, evaluate, and manage the risks posed by indirect links to sanctioned parties. In particular, the document provides detailed direction...

General

10 Sep, 2025

BIS Final Rule Relaxes Export Controls on Syria

In a final rule scheduled for publication in the Federal Register on September 2, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) formally implemented sweeping changes to the Export Administration Regulations (“EAR”) as they pertain to the Syrian Arab Republic. The action follows Executive Order 14312, Providing for the Revocation of Syria Sanctions, issued on June 30, 2025, in which the...

General

9 Sep, 2025

OFAC Penalizes Freight Forwarder Fracht FWO $1.6 Million for Multiple Violations of Sanctions Programs

On September 3, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1,610,775 settlement with Fracht FWO Inc. (“Fracht”), an international freight forwarder headquartered in Houston, Texas, in connection with apparent violations of multiple U.S. sanctions programs, including those targeting Venezuela and Iran. The matter arose from a May 2022 transaction in which Fracht, responding to urgent customer demands,...

General

22 Jul, 2025

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich, Connecticut—agreed to remit $11,832,136 to resolve its potential civil liability for a staggering 12,367 apparent violations of multiple U.S. sanctions programs. The violations, which spanned from approximately July 15, 2016 through January 31, 2024, implicated...

General

15 Jul, 2025

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a publicly traded designer and supplier of power semiconductors headquartered in Sunnyvale, California. The agency concluded that AOS committed fifteen violations of the Export Administration Regulations (“EAR”) between May and November 2019 by exporting a...

General

10 Jul, 2025

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and freight forwarding firm headquartered in Delaware, to resolve Key Holding’s potential civil liability for apparent violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. part 515. The apparent...

General

2 Jun, 2025

OFAC Recalibrates Syria Sanctions in Response to Regime Change

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of U.S. economic policy toward Syria. Acting in close coordination with the Department of State’s issuance of a national security waiver under Section 7425 of the Caesar Syria Civilian Protection Act of 2019...

General

7 May, 2025

Voluntary Self-Disclosure Shields Universities Space Research Association from Prosecution by DOJ

On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and fulsome voluntary self-disclosure of export control violations perpetrated by a former employee. The declination, conveyed through a detailed letter signed by Principal Deputy Assistant Attorney General David Newman, marks one of the clearest applications...

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