Trade Compliance
Guides & Insights

The Bureau of Industry and Security requires exporters to retain screening records for five years under 15 CFR Part 762. But retention alone won't save you when auditors show up. What matters is whether your records tell a coherent story—what you screened, when, against which lists, and what you did with the results.

A 150-person electronics distributor running 100 shipments monthly against the OFAC SDN list needs approximately 8-12 minutes per party when screening manually. At 100 shipments with an average of 3 parties each, that's 300 screenings. The math works out to 40-60 hours monthly on sanctions screening alone.

OFAC published designation changes on December 18, December 19, and December 23, 2025—three updates in six days. Companies running weekly batch screening had seven days of potential exposure if their batch ran January 9th. The GVA Capital enforcement resulted in $215,988,868—the statutory maximum—partly because the firm failed to detect ongoing exposure to a designated Russian oligarch.

Mid-market exporters screening against 100+ global sanctions lists run into a predictable problem: the same partner triggers hits on multiple lists, and each hit demands separate investigation. A machinery distributor screening a single UAE counterparty may pull alerts from OFAC's SDN, the EU Consolidated List, UK OFSI, the BIS Entity List, and three UN committee lists. Seven investigations for one partner.

OFAC's June 2025 settlement with Unicat Catalyst Technologies traced back to a single regional distributor operating across the UAE and Iran. The $3.88M penalty originated from inadequate third-party screening at onboarding. Vetting foreign distributors before signing isn't optional caution—it determines whether your company becomes the next enforcement example.

Cadence Design Systems agreed to pay $140 million in combined BIS-DOJ penalties in July 2025 for export violations that started with a single missed connection: software downloads to an entity that had been on the Entity List since 2015. Red flags aren't theoretical compliance exercises—they're the specific behavioral patterns regulators use to determine whether your export compliance program actually works.

The Bureau of Industry and Security can assess $374,474 per violation as of January 2025. That figure means nothing until an OEE Special Agent asks for your export documentation and you realize three years of ECCN determinations are scattered across email threads, personal drives, and a former employee's laptop that IT wiped six months ago.

On January 10, 2025, OFAC designated 37 individuals, 203 entities, and 184 vessels linked to Russia's energy sector in a single action. Five days later, another 250 parties followed. When a supplier you're actively doing business with lands on the SDN list mid-contract, the clock starts running immediately.

OFAC published 1,811 sanctions list updates in 2025 through late December (Treasury.gov). When a Thursday afternoon designation hits a consignee you cleared on Wednesday morning, your "screened and approved" shipment becomes a compliance gap sailing toward a $377,700 civil penalty. The SDN list doesn't pause for cargo ships.