Trade Compliance
Guides & Insights

BIS added 170+ entities to the Entity List through October 2025. When your supplier or customer shows up on that list mid-contract, you have roughly 30 days to figure out whether you can complete shipments already in transit. Beyond that window, every export, reexport, or transfer requires a license — and BIS reviews Entity List applications under a presumption of denial.

OFAC's $215.9 million penalty against GVA Capital traced back to a single failure: the firm managed investments for a Russian oligarch without verifying who actually owned the underlying fund structure. The oligarch wasn't listed as a direct investor—he was buried three layers deep in a UBO chain that GVA never bothered to chase down.

OFAC designated Rosneft and Lukoil on October 22, 2025. The EU adopted its 19th sanctions package the following day, October 23. That's an 8-day gap from the UK's October 15 designations. Coordinated? Technically. Synchronized? Not operationally. If your sanctions screening ran once on October 16 and again on October 24, you had an eight-day window where you were compliant with one authority but exposed to another.

BIS added nine Turkish companies to the Entity List in a single October 8, 2025 action—one of the most sweeping designations against intermediary networks supporting Iran ever recorded. That designation sent a clear message: routing goods through third countries offers no protection when the final destination is sanctioned territory.

The average OFAC screening false positive rate sits between 5% and 6% for organizations running properly calibrated systems. That sounds manageable until you run the math: a mid-market exporter processing 200 screenings daily generates 10-12 false positives requiring manual investigation. Each investigation consumes 15-25 minutes of analyst time.

OFAC's 50% rule blocked Rosneft, Lukoil, and 34 subsidiaries on October 22, 2025. But the SDN list named only the parent companies. Their downstream joint ventures, minority stakes, and affiliate structures? Those don't appear anywhere you can search. A parts distributor screening "Lukoil Marine Bunker LLC" gets zero hits. The entity is blocked anyway because its ownership math crosses the 50% threshold.

The EU's Delegated Regulation 2025/2003 entered into force on November 15, 2025, adding quantum computers, semiconductor manufacturing equipment, and additive manufacturing items to Annex I. For the first time, the Commission inserted controls that Russia vetoed at the Wassenaar Arrangement since the Ukraine invasion began in February 2022.

BIS added 29 entries to the Entity List effective October 8, 2025—19 under China, 9 under Turkey, 1 under UAE. Nine days earlier, the Affiliates Rule expanded export restrictions to any company owned 50% or more by a listed entity. Learn how dual-use supply chains face amplified exposure across multiple regulatory regimes.

OFAC published sanctions updates on 10 separate days during December 2025: the 3rd, 9th, 10th, 11th, 12th, 16th, 17th, 18th, 19th, and 23rd. A shipment cleared on December 17 against a Dubai-based ship manager who got designated on December 18 becomes a compliance problem nobody warned you about.