Trade Compliance

OFAC Designates Rwanda Defence Force and Officials; Issues General License

The US Treasury's OFAC has designated the Rwanda Defence Force and four Rwandan officials under its Specially Designated Nationals (SDN) List for actions related to the Democratic Republic of the Congo. OFAC also issued DRC-related General License 1 to authorize the wind-down of transactions involving the Rwanda Defence Force.

BIS Fines Teledyne FLIR $1M for Unlicensed China Exports

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) settled with Teledyne FLIR for $1,000,000 over alleged violations of the Export Administration Regulations (EAR). The violations involved unlicensed exports of thermal imaging cameras to China and miscalculations under the de minimis rule.

Switzerland Updates ISIL and Al-Qaida Sanctions List

Switzerland's State Secretariat for Economic Affairs (SECO) announced an update to its sanctions list concerning individuals, groups, undertakings, and entities associated with ISIL (Da'esh) and Al-Qaida. The update reflects amendments made by the UN sanctions committee, entering into force in Switzerland without delay.

OFAC Delists Altomare SA and Vessel Kallista from SDN List

The U.S. Office of Foreign Assets Control (OFAC) announced on January 21, 2026, the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals (SDN) List. The entities were originally designated in November 2025.

UK Sanctions List Consolidation

The UK's Foreign, Commonwealth and Development Office is consolidating its sanctions designations into a single UK Sanctions List (UKSL) effective January 28, 2026. This change aims to reduce non-compliance risk by simplifying identification of sanctioned individuals and entities, without altering the scope of sanctions or business obligations.

CBP Launches Mandatory Forced Labor Portal for Importers

U.S. Customs and Border Protection (CBP) has launched a new, mandatory online Forced Labor Portal for importers to submit requests challenging shipment detentions or exclusions related to forced labor enforcement. This centralized platform replaces previous submission methods and is effective immediately.

OFAC Launches New Online Voluntary Self-Disclosure Portal

The U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) has launched a new online Voluntary Self-Disclosure (VSD) Portal to streamline reporting of potential sanctions violations. The portal aims to improve process visibility and communication for disclosing parties, and OFAC strongly encourages its use.

Treasury Seeks Input on CFIUS Investor Program and Streamlining Reviews

The U.S. Department of the Treasury's Office of Investment Security has published a request for information seeking public comments on streamlining the Committee on Foreign Investment in the United States (CFIUS) review process. Feedback is requested on a proposed Known Investor Program and other streamlining measures, with comments due March 18, 2026.

US Imposes Export Controls on AI Chips to China, Tariffs

The US Department of Commerce's Bureau of Industry and Security (BIS) issued a final rule on January 15, 2026, revising its export licensing review policy for advanced computing items to China. This change shifts from a presumption of denial to a case-by-case review for certain AI chips, while also imposing a 25% fee on such sales. Concurrently, a Section 232 Proclamation targets semiconductor imports with tariffs, offering exceptions for domestic use.

OFAC Issues Venezuela Oil Trade General Licenses

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued General License (GL) 46, authorizing certain transactions related to Venezuelan oil and petroleum products for established U.S. entities. This action aims to expand trade and investment opportunities, though broader sanctions remain in place.