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June 2025 Export Practitioner

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Welcome to your June Export Practitioner
Our companion Washington Tariff & Trade Letter provides a weekly digest and analysis of Trade Security topics, as well as a deeper discussion of Tariffs, which are of growing interest to all practitioners. For a complimentary trial subscription to the WTTL, just drop us a line at info@exportprac.com.
The investigation also uncovered procurement documents and communications related to radio infrastructure development in Kursk, near the Russia–Ukraine border.
Guilty Plea in Radio Export Scheme
A man arrested in connection with a scheme to illegally export U.S.-origin radio communications technology to Russian end users without a license pleased guilty in US District Court in Washington June 17.
Iran Pressure Continues to Build
The U.S. Treasury and State Departments announced a series of coordinated sanctions and regulatory actions to pressure the Iranian regime. Recent measures target Iran’s shadow banking operations, oil smuggling network, and military procurement activities.
Currency Export Rules Review
The Treasury’s Financial Crimes Enforcement Network (FinCEN) has published a Federal Register notice reaffirming existing rules requiring individuals and certain entities to file Form 105—the Report of International Transportation of Currency or Monetary Instruments (CMIR)—for physical transfers exceeding $10,000 entering or leaving the United States.
Venezuelan Mill Supply Arrests
The Justice Department announced today the arrests of two men on charges of conspiracy to violate U.S. sanctions, smuggling, and international money laundering. The arrests stem from a scheme to supply restricted industrial goods to Complejo Siderúrgico de Guayana S.A. (COMSIGUA), a sanctioned Venezuelan state-owned steel manufacturer.
Sanctions Declination for Self-Disclosure
The Justice Department announced it has declined to prosecute White Deer Management LLC, a private equity firm, after the firm voluntarily self-disclosed criminal violations of U.S. sanctions and export control laws committed by an acquired company, Unicat Catalyst Technologies LLC (Unicat).

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