Trade Compliance
Guides & Insights

BIS revoked Hong Kong's preferential licensing treatment in mid-2020, effective immediately. One Federal Register notice, and a jurisdiction that had operated under favorable License Exception provisions for decades got yanked into the same export control framework as mainland China.

Our team tracked 847 temporary export shipments across our customer base in 2025. Nearly one in five ran into problems on the return leg — not the outbound shipment, the re-import. Demo equipment stuck in German customs for three weeks because someone forgot to file CBP Form 4455 before departure.

OFAC's SDN list contains 12,847 entries with over 47,000 aliases, transliterations, and name variations. Your screening algorithm returns either a match, a potential match, or no match. The problem lives in that middle category—potential matches that could be legitimate customers or sanctioned individuals. No algorithm resolves that ambiguity automatically.

End-user certificates document stated intent; they don't verify actual end-use or end-user legitimacy. BIS enforcement actions increasingly cite inadequate end-user verification as an aggravating factor — even when exporters had signed certificates on file.

OFAC examined audit trail quality in 89% of enforcement actions settled in 2025. The screening result matters less than your ability to prove what you screened, when you screened it, and what you did with the results. Companies with solid screening programs face six-figure penalties because their audit trail had gaps. The screening happened. The documentation didn't.

Where manual sanctions screening falls apart, what automation actually costs compared to spreadsheets and consultants, and which scenarios tip the math toward switching.

BIS issued 89 warning letters in 2025, up 34% from the prior year. A warning letter isn't a fine—not yet. But how you respond over the next 30–60 days determines whether this becomes a closed file or the opening chapter of a formal enforcement case.

A German subsidiary of a US aerospace company shipped controlled components to a UAE distributor in March 2023. The components never touched US soil. Manufacturing happened in Munich, shipping originated from Frankfurt. Eight months later, BIS issued a $3.2 million penalty — against the US parent in Texas.

BIS assessed a civil penalty of $374,474 against a British Virgin Islands company in September 2025 for a single unlicensed aircraft reexport to Russia. That figure represents the current maximum administrative penalty per violation under the Export Administration Regulations — and the floor is far higher when the transaction value exceeds roughly $187,000 or when multiple shipments are involved.