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Russian diesel deal challenges congressional sanctions policy and divides allies

The diesel agreement puts the administration’s drive to lower fuel prices before the midterms at odds with Congress’s effort to deny Moscow revenue for its war against Ukraine and Britain’s commitment to maintaining sanctions pressure.

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Export Practitioner Oct. 2026

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FMC Proposes Vessel Fees and Spanish Import Restrictions

The Federal Maritime Commission has proposed a $200,000 fee on Spanish-flagged vessels entering U.S. ports and restrictions on selected Spanish exports, escalating a dispute over Spain’s denial of port access to vessels carrying cargo bound for or coming from Israel. The proposal would extend the dispute to U.S. importers of Spanish olive oil, cosmetics, ceramics, and other goods.

China Hawks Seek to Strip COSCO Vessels of Inspection Privileges Over Espionage Allegations

The dispute puts COSCO’s access to reduced U.S. port inspections under scrutiny as lawmakers press the Coast Guard to account for national security risks alongside vessel safety. COSCO has denied the espionage allegations, saying its onboard equipment serves legitimate commercial purposes.

Carlyle Exits Lukoil Sale as Rival Consortium Pursues Assets

U.S. private equity firm Carlyle Group has abandoned its active pursuit of Lukoil's international assets after its acquisition agreement expired without Treasury Department approval, leaving a consortium led by investor Todd Boehly among the remaining contenders for the Russian oil company's overseas business.

Europe Broadens Russia Sanctions

The European Union added 1,646 persons and entities to its Russia sanctions list on October 12, increasing the number of designations under its Ukraine territorial-integrity regime by about 35%, to nearly 4,600.

Canada’s Deemed Ownership Guidance

Global Affairs Canada (GAC) has published guidance on Canada’s sanctions deemed ownership provisions, addressing when a listed person’s control of an unlisted entity can bring that entity’s property within sanctions restrictions. The guidance warrants attention from financial institutions, businesses and counsel assessing counterparties with complex ownership or governance arrangements.

China Proposes Broader Technology Export Controls; Registration Takes Effect Immediately

The proposal would extend China’s technology export controls across three strategic industries, with consequences for overseas licensing, technology transfers and changes in ownership or control. Although the proposed prohibitions and restrictions remain under consultation, the immediate registration requirement means companies must assess pending transactions now, including transfers already underway.

Venezuela: OFAC Removes Delcy's Brother from SDN List

The U.S. Treasury Department’s Office of Foreign Assets Control removed Jorge Jesús Rodríguez Gómez, president of Venezuela’s National Assembly, and brother of Delcy Rodríguez, Venezuela’s acting president, from its Specially Designated Nationals and Blocked Persons List. OFAC also extended General License 60, permitting earthquake relief transactions otherwise prohibited by the Venezuela Sanctions Regulations.

OFAC Warns Foreign Banks of Iran Sanctions Without Advance Notice

The U.S. Treasury Department’s Office of Foreign Assets Control warned foreign financial institutions on October 5 that continued dealings with Iran or its financial sector could expose them to sanctions under Operation Economic Outcast. The alert states that institutions transacting with sanctioned Iranian financial institutions could be targeted “at any time without advance notification” and urges them to terminate those activities and relationships.

Green Card Crackdown May Increase Offshore Export-Control Risk

The Trump administration’s suspension of Microsoft, Adobe and six major IT-services companies from the federal permanent labor certification program could produce an unintended trade-compliance consequence: greater reliance on personnel working outside the United States and more cross-border transfers of controlled technology.

Almost Everything “Can Be” Dual-Use

Can almost any civilian product qualify as a dual-use item? Ross Denton , Senior Counsel at Akin Gump in London, raises that question in his discussion of Advocate General Tamara Ćapeta’s Opinion …

Aircraft-Part Licensing Slowed for China

Commerce is reportedly delaying aircraft-parts licensing for China, using access to U.S. aviation supplies as leverage in trade negotiations. Slower approvals and limits on quantities licensed raise delivery risks in a market that bought $15.9 billion in U.S. civilian aircraft, engines, equipment and parts in 2025.

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Licensing

State Proposes Broader ITAR Revisions Following Country-Policy Changes, Underwater-Vehicle Rule, and Corrections

The State Department’s Directorate of Defense Trade Controls has proposed revisions to the U.S. Munitions List, key ITAR definitions, and licensing exemptions. The proposal follows September actions revising country policies, narrowing controls on uncrewed underwater vehicles, and correcting inadvertent deletions from exemption provisions.

Russia Lab Death Sharpens Debate Over Biotechnology Controls

An unexplained death at a Russian high-containment biological research facility is putting renewed attention on a problem that U.S. export-control officials have been confronting for several years: biotechnology is advancing faster than the regulatory architecture intended to keep dangerous biological capabilities from proliferating.

State Proposes USML Reductions, “Specially Designed” Changes, and New Repair Exemption

The State Department’s Directorate of Defense Trade Controls is scheduled to publish a proposed rule on October 1 that would narrow U.S. Munitions List controls, revise key ITAR definitions, and establish a license exemption for temporary exports of foreign defense articles for servicing and repair.

Import regulation and export controls: "two sides of the same coin"

In the waning days of Summer, we sat down with Nazak Nikakhtar, former Commerce Department official and current Chair of Wiley Rein's National Security Practice to hear her thoughts on ECRA, the Entity List, BIS-ITA interplay, and navigating a career in private practice and public service.

People

Andrea Gacki Leaves Record of Pragmatic Enforcement

Andrea Gacki is closing a 25-year career in federal service with an enforcement action that neatly captures her approach: exacting about failures, skeptical of paper compliance and focused on whether financial controls work in practice.

BIS Nominee: Export Controls Must Balance Security and Economics

Abby Warren, President Donald Trump’s nominee to lead export administration at the Commerce Department’s Bureau of Industry and Security, told the Senate Banking Committee July 23 that export controls should address significant national-security risks while accounting for their economic impact

Practitioner Profile: Tim O'Toole

The always cool and ever-original Tim O’Toole, practice lead for Miller & Chevalier Chartered’s export controls and sanctions team, indefatigable compliance educator and host of the Embargoed! Podcast took some time ahead of Independence Day to talk enforcement trends.

Erich Ferrari: 'Sanctions are simple, but they're not easy.'

For businesses and individuals who find themselves on the Office of Foreign Assets Control’s Specially Designated Nationals list, a few firms stand out that offer hope for redemption. Ferrari & Associates is one of them. With 17 years of experience advising clients on how to get off OFAC’s list or avoid sanctions in the first place, founder Erich Ferrari has racked up wins, bringing more than a few blacklisted entities back to life from the designation known as “civil death.”

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Practitioner Profile: Mario Mancuso

Before the semiconductor tensions of the 2020s and the export control reforms of the 2010s, Mario Mancuso led the Bureau of Industry and Security in the final years of the Bush administration — pushing the agency toward greater prominence and deeper national security impact.

Practitioner Profile: Sarah Gerdes

West Coast attorney Sarah Gerdes joined Akin’s international trade practice in Los Angeles at the start of the year as part of its national security & global investigations team after a distinguished tenure in the U.S. Attorney’s Office for the Central District of California, where she most recently served as the Deputy Chief of the National Security Division and Assistant U.S. Attorney. In conversation with The Export Practitioner, edited for length and clarity below, she shared lessons from her experience leading national security investigations and advice for meeting the current moment in enforcement.

Q&A with Ryan Fayhee

Ryan Fayhee, now a partner at Akin Gump, led the issue with his contribution on extradition in export enforcement cases. The piece urged prosecutors to emphasize the deception rogue exporters and middlemen undertake to thwart U.S. national security restrictions in order to sway foreign counterparts, as well as the proper interpretation of dual-criminality treaties. The article was published near the end of Fayhee’s illustrious 11-year run at the U.S. Department of Justice, where he cut his teeth on cross-border investigations covering espionage, sanctions and embargoes, arms proliferation, trade secret theft, cybercrime, corruption, and money laundering. He capped his tenure in the department’s National Security Division as the government’s principal attorney for sanctions and export control prosecutions. Fayhee granted The Export Practitioner an interview, edited for length and clarity below, to discuss how international collaboration in export controls has evolved, how investigations look from the private sector and his ongoing work to bring people back to the U.S.