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Russian diesel deal challenges congressional sanctions policy and divides allies

The diesel agreement puts the administration’s drive to lower fuel prices before the midterms at odds with Congress’s effort to deny Moscow revenue for its war against Ukraine and Britain’s commitment to maintaining sanctions pressure.
International Criminal Court, The Hague, Netherlands
The licenses avert an immediate operational shutdown but leave the ICC under sustained U.S. leverage. Routine subscriptions, telecommunications and enterprise software may continue—some indefinitely, others only through April 7, 2027—but vendors must still screen separately sanctioned officials and may withdraw services voluntarily.

DOJ Signals Broader Criminal Exposure in Qui Tam and Trade Fraud Matters

The directive signals that trade-fraud and qui tam matters may no longer remain discrete civil investigations. Allegations involving unpaid duties, false origin claims, undervaluation, misclassification or forced labor may prompt parallel criminal, tax, securities and asset-forfeiture inquiries. Importers and other supply-chain participants should investigate credible allegations promptly, preserve evidence and assess disclosure options before DOJ independently identifies the conduct.

California Executive Charged in $300 Million AI Server Export Scheme

A California technology executive was arrested October 1 on charges that he helped smuggle more than $300 million in export-controlled computer servers to China through intermediaries in Malaysia and Singapore.

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Welcome to Your WTTL

The Washington Tariff and Trade Letter introduces a web-based format for easier review, research and sharing.  Clicking on a story in the newsletter will now bring you to the full text on our new web site. A .pdf version of the newsletter is available below.   For any questions about website access and your subscription, please contact us at Info@TradeRegs.com – Or call the Editor, Frank Ruffing, at +1.703.283.5220

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Vol 46 No. 41, October 12, 2026

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Canada’s Deemed Ownership Guidance

Global Affairs Canada (GAC) has published guidance on Canada’s sanctions deemed ownership provisions, addressing when a listed person’s control of an unlisted entity can bring that entity’s property within sanctions restrictions. The guidance warrants attention from financial institutions, businesses and counsel assessing counterparties with complex ownership or governance arrangements.

Tianmen Square

China Proposes Broader Technology Export Controls; Registration Takes Effect Immediately

The proposal would extend China’s technology export controls across three strategic industries, with consequences for overseas licensing, technology transfers and changes in ownership or control. Although the proposed prohibitions and restrictions remain under consultation, the immediate registration requirement means companies must assess pending transactions now, including transfers already underway.
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DOJ Seeks $290 Million From Uni-Tile and CEO in Customs Fraud Suit

The Justice Department is seeking approximately $290.4 million in unpaid duties and fraud penalties from Uni-Tile & Marble Inc. and its chief executive officer, Xin Mian Pan, in a civil customs enforcement action that examines their alleged role in imports entered through other companies.

Old town Stockholm, Sweden at sunset.

Russian National Extradited from Sweden in Alleged Scheme to Divert U.S. Electronics to Russia Through Hong Kong

A Russian national extradited from Sweden faces federal charges for allegedly using a Hong Kong electronics company to obtain U.S. components for Russian customers, conceal their ultimate …
A 9K38 Igla (SA-18) portable surface-to-air missile system in Brazilian Army service.

Bosnian Arms Dealer Sentenced to Five Years for North Korea Sanctions Violations

Sasa Micev, a Bosnian national, was sentenced to five years in federal prison after pleading guilty to violations of the International Emergency Economic Powers Act and the North Korea Sanctions Regulations arising from an attempted purchase of North Korean anti-aircraft missiles, the Justice Department announced October 14, 2026.

OFAC Removes Key Maduro Ally from SDN List

The U.S. Treasury Department’s Office of Foreign Assets Control removed Jorge Jesús Rodríguez Gómez, president of Venezuela’s National Assembly, from its Specially Designated Nationals and …
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The Department of Commerce’s Bureau of Industry and Security has issued guidance defining “U.S. content” for tariff treatment under clause (2)(d) of Proclamation 11032. The guidance concerns products of Canada and Mexico that qualify for preferential treatment under the United States–Mexico–Canada Agreement. Its practical significance turns on how importers establish and value qualifying U.S. content.
The action casts longstanding AML failures as a national security threat, emphasizing Chinese money laundering networks and illicit finance along the southwest border. Beneath that framing, Bank of America admits that deficient controls caused missed or delayed reporting of more than $5 billion in suspicious activity despite repeated warnings.
Rep. John Moolenaar (R-MI) is seeking to find support for legislation restricting federally funded research collaborations with entities on U.S. government restricted lists, releasing a report that challenges objections to stronger safeguards and a supplemental collection of historical investigative records.
International postal shipments entering the United States and the European Union fell sharply after changes to duty treatment for low-value imports, according to the Universal Postal Union’s State of the Postal Sector 2026 report.
OFAC’s $175,015 settlement with Pegasus Worldwide Logistics underscores that sanctions exposure extends beyond deficient screening to incomplete responses during an investigation. The freight forwarder failed to identify a designated supplier despite matching contact information, then took six months to provide a complete subpoena response, prompting six separate reporting violations.

Amidi penalty puts outbound-investment reporting in focus

Treasury’s first outbound-investment penalty shows that a missed filing can carry substantial consequences even when the government has not alleged that the underlying investment was prohibited.

Green Card Crackdown May Increase Offshore Export-Control Risk

The Trump administration’s suspension of Microsoft, Adobe and six major IT-services companies from the federal permanent labor certification program could produce an unintended trade-compliance consequence: greater reliance on personnel working outside the United States and more cross-border transfers of controlled technology.

American Express Bank Fined $350 Million for AML Failures in Trade-Based Activity

The case illustrates how an AML program can fail when its risk assessment does not reflect its core business. Regulators found that American Express gave insufficient attention to its dominant credit and charge card operations, allowing weaknesses in customer due diligence, transaction monitoring and reporting to persist for years.
U.S. Court of International Trade, New York

Trade Court Seeks New Briefs in Section 301 Forced-Labor Case

A three-judge panel at the Court of International Trade has asked for additional briefing in the lead challenge to USTR’s Section 301 forced-labor duties, narrowing the dispute into threshold and merits questions that could determine both whether the action survives and how broadly any relief would apply.

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