ExportLawBlog

An OFAC enforcement release issued on October 27, 2026, announced that a North Carolina company agreed to pay $1,529,685 to settle its potential civil liability for nine apparent violations arising from its dealings with a blocked Russian entity. The release noted that the company’s U.S.-led compliance team reviewed a March 2018 purchase agreement entered into […]

Last week OFAC, pursuant to Executive Order 13902, placed Karnakis and Karnakis, a law firm operating in Greece and Panama, on the SDN list for “operating in the petroleum and petrochemical sectors of the Iranian economy.” The agency justified this surprising conclusion by saying this: Karnakis and Karnakis has for years leveraged its legal practice […]

Language in the recently proposed ITAR amendments may reveal one of those worst nightmare scenarios that have been frightening people for years (and not just at Halloween). You buy a 3A611.x part from a vendor, you put it in a product you manufacture and sell, and then, after you have thousands of your product in […]

Without question, the definition of “Defense Services” has been one of the most controversial provisions of the International Traffic in Arms Regulations. Going back to 2011, DDTC first proposed revising the definition of “defense services” and infamously said this: [I]t was determined that the current definition of defense services in §?120.9 is overly broad, capturing […]

Pegasus Worldwide Logistics, a small company with about a dozen employees, agreed to pay a penalty of $175,015 for arranging a shipment for a U.S. customer of a sugar-packet filling machine valued at $5,950 from a Chinese firm on the SDN List for narcotics-related activities. In addition, OFAC charged Pegasus with six other violations arising […]