Trade Compliance Brief - Export Control and Sanctions Insights

The Intermediary Illusion: Unpacking OFAC’s $1M Sectoral Sanctions Settlement with FTI Consulting

In this episode, we break down the critical compliance lessons from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) June 1, 2026, enforcement release. Global business advisory firm FTI Consulting, Inc. has agreed to pay $1,050,000 to settle potential civil liability for apparent violations of Russia-related sectoral sanctions. The case centers on a fundamental compliance blindspot: attempting to structure an engagement through an intermediary law firm to provide services to a blocked entity on the Sectoral Sanctions Identification (SSI) List. We dissect how FTI indirectly extended credit to Russia's state-owned VTB Bank by issuing invoices that went unpaid long past the permissible 14-day maturity period under Directive 1 of Executive Order 13662. Key Takeaways for Compliance Professionals: * The "Indirect" Prohibition: You cannot do indirectly what you are prohibited from doing directly. OFAC scrupulously examines the underlying economic and practical realities of formal billing structures. * Invoices as New Debt: Under Directive 1, issuing an invoice to an SSI-listed entity (or for its benefit) constitutes an extension of debt. If those invoices remain unpaid past the regulatory threshold (14 days), you are actively dealing in prohibited debt. * Credit Risk & Warning Signs: Continuing to perform valuable services and issuing subsequent invoices while prior bills are heavily overdue constitutes a major regulatory warning sign. * Intermediary Shielding Fails: Relying on a law firm's client relationship or unique billing terms does not absolve a technical service provider from direct sanctions liability. Keywords: OFAC enforcement, Trade Compliance, Sectoral Sanctions, Directive 1, Russia Sanctions, VTB Bank, FTI Consulting, Extension of Debt, SSI List, Law Firm Compliance, Corporate Risk Management, URSR.

OFAC's $275M Adani Settlement: The Cost of Ignoring Third-Party Sanctions Red Flags

In this episode, we break down the historic $275 million settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and India’s Adani Enterprises Limited (AEL) announced in May 2026.  This case represents a watershed moment for non-U.S. companies operating in high-risk energy corridors, highlighting how easily a foreign entity can trigger severe U.S. civil liability through a U.S. dollar clearing nexus.  What We Cover: • The Mechanics of Evasion: How 32 apparent violations occurred through the procurement of Iranian-origin Liquefied Petroleum Gas (LPG) masked by falsified Omani and Iraqi certificates of origin. • The U.S. Dollar Nexus: How $192 million processed through U.S. financial institutions established strict OFAC jurisdiction over a non-U.S. corporation. • The Anatomy of a Blind Spot: Why OFAC designated this case as "egregious" after AEL repeatedly dismissed four separate third-party compliance warnings regarding their Dubai-based supplier as mere competitor interference. • Enforcement Lessons: What this record-setting enforcement action teaches us about sector-specific due diligence, vessel tracking, and looking past standard commercial explanations. Whether you manage an international supply chain or oversee corporate sanctions screening, the compliance failures in this case offer a vital roadmap for risk mitigation. Keywords: Trade Compliance, Sanctions Enforcement, OFAC, Adani Enterprises, Iran Sanctions, ITSR, Export Controls, Maritime Compliance, Red Flags, U.S. Dollar Clearing, Supply Chain Risk, Corporate Governance.

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.