Trade Compliance Brief - Export Control and Sanctions Insights

Inside the $36M GE Aerospace ITAR Settlement

In this episode, we break down the major April 2026 Directorate of Defense Trade Controls (DDTC) enforcement action against GE Aerospace. Securing a $36 million civil penalty and a 36-month Consent Agreement, this case is an essential case study for international trade compliance professionals. We dissect the 116 ITAR violations, including the infamous "unattended laptop in China" incident, manual overrides of automated export compliance systems, and unauthorized technical data transfers to global sublicensees. Tune in as we analyze the cost of antiquated procedures and extract the key operational takeaways your compliance team needs to implement today to avoid a DDTC audit.

US Cuba Sanctions Update: The May 1st EO, Sectoral Sanctions, and FFI Secondary Risks

On May 1, 2026, a sweeping new Executive Order fundamentally reshaped U.S. sanctions policy toward Cuba. Moving beyond the traditional list-based approach, this new framework introduces Sectoral Sanctions and high-stakes Secondary Sanctions for Foreign Financial Institutions (FFIs). In this brief, we analyze the "Russia Playbook" application to Cuba and what it means for global compliance programs. In this episode, we cover: * The Sectoral Pivot: Identifying the five newly targeted sectors: Energy, Defense, Metals/Mining, Financial Services, and Security. * The FFI "Death Penalty": Understanding the risk of losing U.S. correspondent account access under the new secondary sanctions authorities. * E.O. 14024 vs. The Cuba EO: Why the U.S. is mirroring the Russian Harmful Foreign Activities framework. * Compliance Red Flags: New triggers for human rights abuses and public corruption. * Operational Checklist: Immediate steps for KYC updates and screening for "Adult Family Members" of designated persons.

Poland’s €4.7M Crackdown: How Luxury Cars Secretly Reached Russia

Despite Western trade restrictions, luxury goods are still making their way into Russia. This episode breaks down Poland's recent enforcement actions, including a €4.7 million penalty and multiple arrests, against networks illegally exporting millions of euros worth of luxury vehicles. Learn how transit routes and fraudulent documents are being used to feed the Russian market.

US Export Licensing Delays Costs Billions

In this episode, we dive into the growing crisis in U.S. export licensing based on a recent survey by the CSIS . We explore how the Bureau of Industry and Security (BIS) is facing unprecedented backlogs, with more than half of surveyed tech exporters waiting over 180 days for license reviews—well beyond the 90-day statutory limit. Discover how these extended timelines and a lack of transparency are leading to billions of dollars in delayed exports and costing companies critical business to foreign competitors. Finally, we unpack practical policy solutions to align national security goals with the administrative realities of globally competitive markets. CSIS Report: https://csis-website-prod.s3.amazonaws.com/s3fs-public/2026-04/260421_Koren_Delays_Uncertainty.pdf?VersionId=tiMPZcvtOn7Pgapw7Ake8GQKfAyG2inA

UK Sanctions Strategy 2026-29: The PERC Framework & AI Enforcement | OFSI Deep Dive

The UK’s Office of Financial Sanctions Implementation (OFSI) has entered its second decade with a high-stakes mandate. In this episode, we break down the newly released OFSI Strategy 2026-29, a roadmap that shifts the UK from a reactive posture to a proactive, intelligence-led enforcement powerhouse. If your organization operates in or through the UK, the "PERC" framework is your new compliance North Star. We analyze the strategic shifts every Trade Compliance Officer must know: * The PERC Model: A deep dive into Promote, Enable, Respond, and Change—and what "visibly costly" non-compliance actually looks like in 2026. * AI-Enabled Enforcement: How OFSI is integrating Artificial Intelligence and data analytics to identify circumvention typologies and "zombie" financial networks. * New Performance Targets: Discussion of the aggressive new KPIs, including a commitment to close 50% of licensing cases within 6 months and submit 90% of investigations within 18 months. * Intelligence-Led Outcomes: Why the era of relying solely on voluntary self-disclosures is over, as OFSI moves toward proactive case origination. * International Cooperation: The "Enhanced Partnership" with OFAC (US) and the EU, aiming to eliminate jurisdictional arbitrage for multinational firms. OFSI Strategy Report: https://assets.publishing.service.gov.uk/media/69df6b6d53469bbcdf408e9f/OFSI_Strategy_2026-29.pdf