Global Trade & Sanctions Law

Three recent Department of Justice cases involving exports to Russia highlight a recurring enforcement theme: U.S. companies cannot assess diversion risk based only on the customer and destination named on an order. The cases arose from efforts to evade export controls and sanctions imposed or tightened after Russia’s full-scale invasion of Ukraine in February 2022. In each c...

In just a three-week period starting in September, the State Department’s Directorate of Defense Trade Controls (DDTC) published six rulemakings that make or propose notable changes to the International Traffic in Arms Regulations (ITAR). These include the following:

On October 7, 2026, the U.S. Department of Treasury announced its first civil enforcement penalty imposed under the Outbound Investment Security Program (OISP). For U.S. investment funds, U.S. managers of funds abroad, and U.S. companies with controlled subsidiaries...