The Export Control & Sanctions Watch Edition 33

Arne Mielken
Oct 10, 2025
2 min read

Updated: Oct 16, 2025

Edition 33-2025 - Week 41-2025

Period Covered: 03 October 2025 - 10 October 2025

Published: 10 October 2025

Happy Friday,

It’s time for another edition of the Export Control & Sanctions Watch.

Today, it’s three special reports:

EU 3D Printing Controls: Guides companies on the “All Four” rule, licensing, and compliance risks for advanced metal 3D printers under 2B510.
North Korea Chemical Imports: Reveals key import patterns and dual-use risks for sanctions and compliance monitoring.
AI in AML: Shows how AI improves detection, risk scoring, and real-time monitoring for anti-money laundering.

In our export control section, we revisit the expended BIS Affiliates Rule with a detailed look: We analyse the updated FAQs from BIS and how to helps us understand how this supplies immediately to foreign entities ≥50% owned by Entity List, MEU List, or specified OFAC SDNs, covering branches/offices, strictest licensing rules, and enhanced due diligence.

Next, we explore China’s select rare earths, related tech, and production know-how require approval, including for foreign entities using Chinese inputs. China holds over one-third of global reserves.

On sanctions, there are several developments:

Human Rights: We cover U.S., UK, and EU sanctions targeting human rights violators, including the recent removal of former Paraguayan President Horacio Cartes from OFAC’s Global Magnitsky list.
Narcotics & Drugs: This edition examines sanctions disrupting global drug trafficking, highlighting OFAC’s latest action against Mexican nationals and companies linked to counterfeit fentanyl.
Iran: We review sanctions on Iran’s nuclear, missile, and energy sectors, including recent U.S. and UK measures targeting banks, vessels, and companies facilitating Iranian exports.
Russia: The issue details ongoing sanctions against Russia over Ukraine, covering EU extensions on hybrid threat actors and U.S. removal of a Turkish shipbuilder from its SDN list.