The Export Control & Sanctions Watch Edition 36

Arne Mielken
Oct 30, 2025
2 min read

🎃Spooky Halloween Edition🎃

Edition 36-2025 - Week 44-2025

Period Covered: 24 October 2025 - 30 October 2025

Published: 31 October 2025

🎃 Happy Halloween, Compliance Crusaders! 🕸️

Our cauldron is bubbling with five major stories that are more frightful than a haunted house:

· EU Adopts 19th Sanctions Package Against Russia and Belarus: The EU continues its sanctions siege, delivering another bone-chilling package against Moscow and Minsk.

· Iran, Russia, and the New Zealand Insurer That Kept Their Sanctioned Oil: A complex, web-like case highlighting the difficulty of unwinding financial connections, even at the ends of the earth.

· Dual-Use Classification of Valves – Why It’s Crucial for Compliance: A technical but deadly serious reminder that even seemingly simple items can carry a dual-use curse.

· U.S.–China Bilateral Deal Reached – Key Measures Unveiled: A trade truce that might offer a temporary reprieve from the trade wars, unveiled just as the shadows fall.

· EU's Potential Role in the China-U.S. Trade Deal and Export Control Waiver: Brussels looks to play the witch-doctor role, potentially mediating the biggest trade deal of the season.

Our cauldron is bubbling with these key updates:

· Sanctions & Trade: The EU adopted its 19th Sanctions Package against Russia and Belarus. Separately, a complex case involving an insurer, Iran, and Russia highlighted the difficulty of unwinding sanctioned oil connections. Meanwhile, a U.S.–China Bilateral Trade Agreement was reached in Kuala Lumpur.

· Export Controls: The U.S. Commerce Department faced a setback when a court denied BIS’s motion in the YMTC FOIA case, demanding new transparency expectations for export control decisions. Commerce is also seeking feedback on its AI Export Promotion Program.

· AML & Financial Crime: AML oversight is strengthening globally. AUSTRAC issued guidance ahead of its 2026 expansion to real estate, accounting, and legal sectors. OFAC sanctioned the horrifying Bhardwaj Human Smuggling Organization (Mexico, India, UAE) under its TCO program.

· Key Regime Updates: The EU’s 19th Russia package introduced new LNG import bans. The UK updated its Iran asset-freeze list to strengthen human rights accountability. The UK also formally lifted its arms embargo on Armenia and Azerbaijan.

A truly wicked week for global compliance. Enjoy this read and stay compliant!