Trade Compliance
Guides & Insights

Industry benchmarks put sanctions screening false positive rates between 90% and 95% for most organizations. For every 100 alerts your system generates, fewer than 10 represent actual sanctioned parties. The rest require investigation time that pulls compliance staff away from genuine risk.

Less than 3% of voluntary self-disclosures to BIS result in civil monetary penalties. After the September 2024 regulatory overhaul, BIS now resolves minor violations within 60 days while treating deliberate non-disclosure as an aggravating factor that increases penalties for significant violations.

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.

BIS receives roughly 34,000 classification requests annually. Forty-one percent come back marked incomplete. The Commerce Control List doesn't care what marketing calls your product. It cares about nine technical parameters—and whether those parameters cross specific thresholds.

"It's EAR99, so we're good to ship." Heard that one before. Usually right before something goes sideways. EAR99 means your item isn't on the Commerce Control List. It doesn't mean you can ship it anywhere, to anyone, for any purpose.

License exceptions look like free passes. Ship controlled goods without waiting six months for BIS to process your license application. Until you check wrong. Then you've got a violation that looks worse than if you'd never tried.

OFAC collected $1.54 billion in sanctions penalties during fiscal year 2024, with individual settlements ranging from $4,000 to $508 million. The calculation methodology isn't arbitrary — Treasury follows a published framework in the Economic Sanctions Enforcement Guidelines that compliance teams can reverse-engineer before an apparent violation even reaches formal review.

OFAC enforcement settlements averaged $1.5M per violation in 2025, with screening delays cited as contributing factors in 34% of cases. Your screening provider promises "real-time" results—but what happens when those results take 8 seconds during your busiest shipping hour?

The US Consolidated Screening List pulls 13 federal export screening lists into one free searchable database at trade.gov. Commercial databases aggregate 100-180 lists across multiple jurisdictions — at $3,000 to $100,000+ per year. Most guides frame this as a budget decision. It's not.