Trade Compliance
Guides & Insights

OFAC civil penalties blew past $254M by mid-2025. BIS piled on with over 170 Entity List additions across 6 separate rulings between January and October. And the part that keeps compliance teams awake: none of those penalties landed because someone forgot to screen a counterparty.

BIS published 2,847 updates to the Export Administration Regulations in 2025. Seventeen directly affected license exception eligibility for at least one ECCN category. For compliance teams processing 50–200 shipments monthly, tracking which exceptions apply to which items has turned into a puzzle that resets every few weeks.

A semiconductor distributor shipped $50,000 worth of ICs to a Dubai trading company in January 2025. Two weeks later, enforcement letters arrived from both Treasury and Commerce. Same shipment. Two agencies. Two separate violations.

A 150-person aerospace manufacturer processing 120 shipments monthly spends between $180,000 and $320,000 annually on export compliance. That range matters because most CFOs budget for the low end and hit the high end. The hidden costs account for roughly 40% of total compliance spend.

BIS added 29 entities to the Entity List on October 8, 2025, targeting companies in China, Turkey, and the UAE for supplying Iran with drone components and aviation parts. Three of those entries were addresses only—no company names attached. Most screening tools missed them entirely.

BIS entered 2025 with 585 funded positions and a budget that had roughly doubled over the prior decade. None of that mattered when the February freeze hit. After the 'hold without action' directive, multiple rounds of policy-driven pauses, and a SNAP-R platform migration, the agency entered this year carrying the longest processing backlog in over three decades.

OFAC modified its sanctions lists over 200 times in 2025, averaging 3–4 changes per week. Every one of those changes turned someone's 'screened and cleared' record into a liability. If your screening cadence doesn't match your shipment frequency, you're carrying exposure you haven't priced.

Haas Automation paid $2.5M in combined BIS and OFAC penalties in January 2025 for shipping $29,254 worth of CNC machine parts to Entity List parties in China and Russia. Every single item was classified EAR99, the designation most exporters treat as a free pass.

BIS investigations led to criminal convictions of over 65 individuals and businesses in fiscal year 2024. When an Office of Export Enforcement agent sends a formal document request letter, the clock starts immediately. Here's what BIS actually requests, where most exporters fall short, plus what you can do before the letter arrives.