Foreign Military Sales restrictions
Foreign Military Sales restrictions sit at the center of Trade and Geopolitical Risk compliance right now, with the U.S. Department of State's Directorate of Defense Trade Controls and the U.S. Department of Commerce Bureau of Industry and Security each asserting overlapping authority over end-use controls, re-transfer approvals, and license conditions that govern defense articles moving through commercial supply chains. The Biden-era FMS policy review tightened third-party transfer conditions on several allied recipients, and those conditions are now live in active Letter of Offer and Acceptance agreements that downstream vendors may not have mapped against their own export authorizations. Compliance teams with defense-adjacent supplier relationships are working now to audit those gaps before they become violations.
Watch
- DDTC end-use monitoring conditions on active LOA agreements with Tier 2 allies
- BIS Entity List additions tied to FMS diversion cases in the Indo-Pacific
- Pending Congressional notifications under Section 36(b) of the Arms Export Control Act
- Re-transfer approval backlogs at State affecting time-sensitive commercial offset contracts
Recent material activity in Trade & Geopolitical Risk
-
OFAC designates 14 entities linked to Russian defense procurement network
The Treasury Department's Office of Foreign Assets Control added 14 entities and 6 individuals to the Specially Designated Nationals list for their roles in procuring critical technology components for Russia's defense i…
Read a full sample brief → -
BIS adds 22 Chinese semiconductor entities to Entity List for advanced chip diversion
The Bureau of Industry and Security expanded export controls targeting Chinese semiconductor entities found to be diverting advanced computing chips through third-country intermediaries. New license requirements affect i…
Read a full sample brief →