Trade Compliance Brief - Export Control and Sanctions Insights

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15-Minute AI-Powered Trade Compliance Insights covering Export Controls and Sanctions. Regulations, regulatory developments and enforcement activities.

  1. EU Sanctions Case Study: Tokarev v. Council (T-693/25)

    2D AGO

    EU Sanctions Case Study: Tokarev v. Council (T-693/25)

    In this episode of The Trade Compliance Brief, we dissect the recent filing of Case T-693/25, Tokareva v. Council, at the General Court of the European Union. We analyze the applicant’s grounds for the annulment of restrictive measures and what this litigation means for the future of EU sanctions enforcement. If your firm manages frozen assets or denied party screening, this deep dive into the legal challenges of Council decisions is essential listening. Judgement: https://infocuria.curia.europa.eu/tabs/document/T/2025/T-0693-25-00000000RD-01-P-01/ARRET_NP/315477-FR-1-html

    19 min
  2. OFAC Sanctions & Schools: The $1.7 Million IMG Academy Settlement Explained

    3D AGO

    OFAC Sanctions & Schools: The $1.7 Million IMG Academy Settlement Explained

    When Elite Sports Meets International Sanctions. In this episode, we break down a shocking enforcement action from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). IMG Academy, the world-renowned athletic training facility in Bradenton, Florida, has agreed to a $1,720,000 settlement for apparent violations of counternarcotics sanctions. What happened? Between 2018 and 2022, IMG Academy entered into yearly tuition contracts with two individuals—referred to as SDN 1 and SDN 2—who were sanctioned for their ties to a Mexican drug cartel. Despite the individuals using their real names, which matched the OFAC SDN List, the school failed to conduct basic sanctions screening. Inside this episode: The Details: How the academy processed 89 transactions totaling over $1.7 million for the children of sanctioned "Kingpins". The "Reckless Disregard": Why OFAC determined that minimal due diligence could have prevented these violations.The Pivot: How a change in ownership and a new Chief Legal Officer in 2023 led to a total compliance overhaul. The Warning: Why academic institutions and "domestic" businesses are now in the crosshairs of global sanctions enforcement. Whether you are a compliance officer, a sports fan, or a business leader, this case is a massive wake-up call that "knowing your customer" is no longer optional. Original Source: https://ofac.treasury.gov/media/935006/download?inline

    13 min
  3. The $252M Mistake: Inside the Applied Materials & SMIC Settlement

    6D AGO

    The $252M Mistake: Inside the Applied Materials & SMIC Settlement

    In this episode of the Trade Compliance Brief, we break down the massive $252.5 million administrative penalty issued by the Bureau of Industry and Security (BIS) against semiconductor giant Applied Materials (AMAT). We dissect the failed "dual-build" strategy, where AMAT shifted the assembly of ion implanter equipment from Gloucester, Massachusetts, to South Korea in an attempt to continue selling to SMIC after it was placed on the Entity List. Key takeaways include: The Compliance Trap: Why AMAT’s reliance on "substantial transformation" was legally incorrect and how it differs from U.S.-origin rules under the EAR.The "Is-Informed" Letter: How the company proceeded with shipments despite receiving direct warning of military end-use risks.Strategic Failure: The internal pressure to prioritize revenue over regulatory constraints, resulting in 56 violations. Tune in to understand why moving final assembly abroad doesn't always change an item's origin—and how to avoid a nine-figure fine. Original Documents: https://www.bis.gov/media/documents/2026.02.11-amat-settlement-documents-combined.pdf

    12 min
  4. Tightening of German trade law driven by the integration of EU Directive 2024/1226

    FEB 10

    Tightening of German trade law driven by the integration of EU Directive 2024/1226

    This episode explores critical shifts in German foreign trade law (AWG/AWV) taking effect in on 05.02.2026. https://www.recht.bund.de/bgbl/1/2026/27/VO.html (german only)

    12 min
  5. Fueling the Russian War Machine? The EU Court Ruling on Euro Asia Cargo

    FEB 7

    Fueling the Russian War Machine? The EU Court Ruling on Euro Asia Cargo

    Dive into the General Court’s January 2026 ruling against Euro Asia Cargo, a Sri Lankan logistics firm sanctioned for moving critical Kometa antenna modules found in Russian Geran-2 UAVs. In this episode, we unpack: • The "Kometa Connection": How European antennas ended up in Russian drones via a Sri Lankan transshipment hub. • "Indirect Support": Why the Court ruled that transporting war-critical tech constitutes support for Russia's military complex—even if the shipper claims ignorance. • No Excuses: The rejection of the "freedom to conduct business" defense in the face of international security risks. (powered by AI) EU Ruling: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62024TJ0232

    14 min
  6. Critical Minerals 2026: Project Vault, FORGE, and the Battle for "Real Things"

    FEB 5

    Critical Minerals 2026: Project Vault, FORGE, and the Battle for "Real Things"

    This podcast takes you inside the 2026 Critical Minerals Ministerial in Washington, D.C., where Vice President JD Vance and Secretary of State Marco Rubio unveiled a radical shift in U.S. industrial policy. We explore the administration's "Ironclad" strategy to secure the oil and minerals necessary to power the digital economy, moving beyond "book reports" to direct government equity in mining. Episodes detail the launch of Project Vault, a historic $10 billion domestic strategic reserve, and FORGE, the new global alliance designed to decouple supply chains from adversarial control. We also analyze the controversial proposal for a "preferential trade zone" that uses enforceable price floors to protect allied miners from foreign dumping. (powered by AI) Links to documents: https://www.state.gov/releases/office-of-the-spokesperson/2026/02/2026-critical-minerals-ministerial/ https://www.state.gov/releases/office-of-the-spokesperson/2026/02/opening-remarks-of-the-critical-minerals-ministerial/

    19 min
  7. The Dual-Use Dilemma: How EU Technology Flows to Conflict Zones

    JAN 28

    The Dual-Use Dilemma: How EU Technology Flows to Conflict Zones

    How do European microchips end up in Russian missiles and cyber-surveillance tools reach repressive regimes? In this episode, we break down the January 2026 study "EU trade in dual-use items with conflict-affected regions", authored by Dr. Ian J. Stewart for the European Parliament's Committee on International Trade (INTA),. We explore the gap between the EU’s legal framework (Regulation 2021/821) and the reality of exports to countries like Russia, Israel, and the UAE. Discussion points include: • The "Catch-All" Problem: Why non-listed items (like common electronics) are fueling war machines and evading controls. • Real-World Cases: From the complex corporate network behind Predator spyware to the transit of tapered roller bearings destined for the Israeli defense industry. • Data Black Holes: Why a lack of transparent reporting from Member States makes it nearly impossible to track sanctions evasion and compliance with International Humanitarian Law. (Powered by AI)

    14 min
  8. The US Remote Access Security Act: New Compliance Risks for Cloud Providers on the Horizon

    JAN 26

    The US Remote Access Security Act: New Compliance Risks for Cloud Providers on the Horizon

    With the passage of H.R. 2683, the era of unregulated remote access to U.S. technology is ending. We break down the amendments to the Export Control Reform Act of 2018 (ECRA), which now define "remote access" as a controlled activity alongside traditional exports. Listen in to understand the new licensing requirements for cloud infrastructure providers, the definition of "negligent" access and due diligence challenges for businesses. (powered by AI)

    13 min
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15-Minute AI-Powered Trade Compliance Insights covering Export Controls and Sanctions. Regulations, regulatory developments and enforcement activities.

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