On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that
Altomare SA and Kallista Removed from OFAC’s SDN List
On January 21, 2026, the U.S. Office of Foreign Assets Control (OFAC) announced the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals and Blocked Persons Lists (SDN List).
OFAC originally designated Altomare SA and Kallista in November 2025 as part of a counter terrorism sanctions action
House Passes Remote Access Security Act to Limit Adversaries’ Remote Access to Critical Technology
On January 12, 2026, the U.S. House of Representatives overwhelming passed (369-22) the Remote Access Security Act, modernizing U.S. export controls to address foreign adversaries’ remote access to controlled technologies through cloud computing services.
Currently, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) does not consider the provision of cloud computing
BIS Fines Exyte $1.5 Million for Unlicensed Transfers to China’s SMIC
On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $1.5 million civil penalty on Exyte Management GmbH (“Exyte”), a Germany- headquartered engineering and procurement company, after its Shanghai affiliate Exyte Shanghai Ltd., (“Exyte China”) admitted to illegally causing the transfer of approximately $2.8 million in EAR-subject semiconductor
OFAC Fines U.S. Private Equity Fund for Russian Sanctions Violations
On December 2, 2025, OFAC announced an ~$11 million penalty settlement with IPI Partners, LLC (“IPI”), a Chicago-based U.S. private equity fund, to settle its civil liability for 51 potential violations of OFAC’s Russia sanctions. The enforcement action underscores the importance of diligence to guard against potential sanctions violations. In brief, OFAC found that IPI
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those
BIS Adds 26 Entities, Mostly in China, to the Entity List for Supplying Iran with Drone Parts and U.S.-Origin Electronic Items
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on October 9, 2025 that will add 26 entities and three addresses to the Entity List for a total of 29 new entries (effective immediately). BIS’ Entity Review Committee (ERC)—composed mainly of the Departments of Commerce, State, Defense, Energy, and
BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists
In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or
Client Alert: Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business
On August 28, France, Germany, and the UK (the E3) initiated a “snapback” process that will reimpose UN sanctions on Iran on September 27 unless the Security Council acts. On September 19, a resolution to extend sanctions relief failed to receive sufficient votes at the Security Council and was not adopted. If snapback occurs, previously
BIS Announces Addition of 32 Entities to the Entity List, Including For Exports to Russia
On September 12, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a final rule that announced the addition of 32 new entities to the Entity List (see BIS final rule here). 23 entities were added under the destination of China, one under India, one under Iran, one under