The OverRuled: Sanctions Module has been updated with the following actions:
- 16 Dec 2025 - Exodus Movement, Inc. - USD $3,103,360
Between October 2017 and January 2019, Exodus Movement, Inc. ("Exodus") provided customer support services to users in Iran which, in certain instances, helped such users access third party digital asset exchanges through Exodus's proprietary wallet software. In some instances, while aware of U.S. sanctions, Exodus staff recommended that these users obscure their location in Iran using Virtual Private Networks (VPNs) to avoid the sanctions compliance controls implemented by such exchanges.
The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 15 Dec 2025 - Marco Santillan Jr. - Denial Order; No monetary penalty
BIS issued against Marco Santillan Jr. (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 50 U.S.C. § 4819. The Order went into effect on Respondent’s date of conviction on August 1, 2022. Specifically, Respondent conspired to violate the Export Administration Regulations by conspiring to export firearms and ammunition to Mexico. BIS did not impose any monetary penalty.
- 15 Dec 2025 - Marco Antonio Santillan Valencia - Denial Order; No monetary penalty
BIS issued against Marco Antonio Santillan Valencia (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 50 U.S.C. § 4819. The Order went into effect on Respondent’s date of conviction on January 8, 2024. Specifically, Respondent conspired to violate the Export Administration Regulations by conspiring to export firearms and ammunition to Mexico. BIS did not impose any monetary penalty.
- 15 Dec 2025 - Jose Raul Paredes Arispe - Denial Order; No monetary penalty
BIS issued against Jose Raul Paredes Arispe (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 371 and 50 U.S.C. § 4819. The Order went into effect on Respondent’s date of conviction on October 31, 2023. Specifically, Respondent conspired to smuggle and attempted to export firearms parts and firearms accessories from the U.S. to Bolivia without the required license from the U.S. Department of Commerce. BIS did not impose any monetary penalty.
- 15 Dec 2025 - Nikolay Goltsev - Denial Order; No monetary penalty
BIS issued against Nikolay Goltsev (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 50 U.S.C. § 4819. The Order went into effect on Respondent’s date of conviction on January 8, 2025. Specifically, Respondent exported from dual-use electronic components, items on the Commerce Control List and Common High Priority List, from the United States to Russia without a license from the U.S. Department of Commerce. Over the course of a year, Respondent coordinated the export of over 300 shipments valued at over $7 million USD to Russian military-end users designated on BIS’ Entity List and OFAC’s SDN list. BIS did not impose any monetary penalty.
- 15 Dec 2025 - Richard G. Shih - Denial Order; No monetary penalty
BIS issued against Richard G. Shih (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 371. The Order went into effect on Respondent’s date of conviction on March 13, 2025. Specifically, Respondent conspired to illegally export U.S. goods from the United States to Chinese companies on the U.S. Department of Commerce’s Entity List without required authorization. BIS did not impose any monetary penalty.
- 15 Dec 2025 - Arthur Ching-Fu Gao - Denial Order; No monetary penalty
BIS issued against Arthur Ching-Fu Gao (“Respondent”) a Denial Order for a period of 4 years in relation to violations of 50 U.S.C. § 1701. The Order went into effect on Respondent’s date of conviction on March 10, 2022. Specifically, Respondent exported technical data related to the electronic control unit of legacy aircraft auxiliary power units from the United States to China without the required license from the U.S. Department of Commerce. BIS did not impose any monetary penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 15 Dec 2025 (EU):
The Council of the European Union (the "Council") adopted Council Decision (CFSP) 2025/2594 amending Decision 2014/145/CFSP and Council Implementing Regulation (EU) 2025/2588 implementing Regulation (EU) No 269/2014, sanctioning five individuals and four entities.
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