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Extreme Networks to Pay $2.02 Million Over Russian Defense Sales

The transactions benefited Moscow Machinery Building Plant Avangard, a manufacturer associated with Russia’s S-300 and S-400 air-defense systems.

The case shows how delayed disclosure and unresolved sanctions warnings can turn a modest sales account into a multimillion-dollar enforcement matter. Extreme’s cooperation and remediation secured DOJ’s first “near miss” non-prosecution agreement, but reporting only after a journalist presented new evidence cost it eligibility for a declination.

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Export Practitioner Oct. 2026

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White House Pressure to Unwind Kremlin Sanctions Builds

The Trump administration’s efforts to ease sanctions on Russia could open substantial commercial opportunities for Russian state interests and private investors, combining newly authorized diesel sales with a proposed $25 billion Alaska gas venture and possible relief for the Kremlin’s multibillion-dollar investment fund.

FCC Covered List Enforcement: Conditional Approvals Offer Market Access

The Federal Communications Commission is extending its national-security restrictions deeper into electronics supply chains while allowing specified foreign-produced equipment to enter the U.S. market through conditional approvals. The developments make component sourcing and compliance with approval conditions increasingly important to manufacturers’ access to U.S. customers.

Treasury Proposes Biotechnology Investment Controls

The Treasury Department issued proposed regulations October 22 adding biotechnology to the U.S. outbound-investment screening regime, advancing a central objective of the bipartisan Biotech Investment National Security Act (BINSA).

Lawmakers warn banks and ports of legal risks in Trump’s Russian diesel deal

A bipartisan group of U.S. lawmakers has warned major banks, port authorities and fuel distributors that facilitating Russian diesel imports under President Donald Trump’s agreement with Moscow could expose them to legal action and congressional investigations.

FinCEN Issues Translated Versions of Iran Whistleblower Bulletin

The translations broaden FinCEN’s outreach to potential sources of information on Iran-related illicit finance, including individuals outside the United States. But material errors in several versions could undermine that effort by misstating award percentages, narrowing the apparent scope of sanctions restrictions, or distorting indicators of terrorist financing.

FCC Blocks Two Devices With Huawei Subsidiary’s Chips

The FCC’s action extends the consequences of its national-security restrictions beyond listed companies to manufacturers that use their components. For device makers, a supplier’s choice of semiconductor can now jeopardize access to the U.S. market, increasing pressure to trace components through the supply chain.

OFAC Removes Chinese Cartoon Firm and another Belarusian from SDN List

The removals unwind sanctions imposed in 2021 on Chinese animation businesses and an intermediary accused of supporting North Korea’s SEK Studio, and on a Belarusian executive designated for acting on behalf of state oil and chemical concern Belneftekhim.

UK Proposes Updates to Strategic Export Controls, Including Advanced Technology Restrictions

The proposed amendments would update UK military and dual-use controls, including those covering semiconductor manufacturing equipment, advanced computing and specialised materials; revise country listings for Haiti and the Central African Republic; and phase out GEA001 in Great Britain.

BIS Affiliates Rule Set to Return November 10; Trade Truce Extension Awaits Implementation

The Bureau of Industry and Security’s Affiliates Rule remains scheduled to return on November 10, 2026. The reported extension of the U.S.–China Busan trade agreement through January 10, 2027, could prolong the suspension, but Commerce has not confirmed that the extension covers the rule. Once reinstated, the rule will extend specified Export Administration Regulations restrictions to unlisted foreign entities owned at least 50 percent, directly or indirectly, individually or in the aggregate, by covered parties on the Entity List, Military End-User List or SDN List under sanctions programs identified in EAR § 744.8(a)(1).

FCC Considers ITAR and EAR Compliance Requirements for Satellite Licensing

The Federal Communications Commission is seeking comment on whether satellite and earth station applicants should certify compliance with U.S. export controls, maintain supporting records, and disclose related federal reviews in transactions involving foreign ownership. The proposals would expressly connect FCC licensing with obligations under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR).

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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.