The OverRuled: Sanctions Module has been updated with the following actions:
- 24 Nov 2025 - One Individual - USD $4,677,552
Between April 2023 and March 2024, the individual willfully dealt in residential real property owned by a blocked individual, including by mortgaging, renovating, and selling the property to an unwitting third party.
The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 21 Nov 2025 - Antonio Jose Melean Reyes - Denial Order; No monetary penalty
BIS issued against Antonio Jose Melean Reyes (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 554(a). The Order went into effect on Respondent’s date of conviction on May 3, 2024. Specifically, Respondent smuggled firearms from the United States to Venezuela. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Federick Joseph Bergmann Jr. - Denial Order; No monetary penalty
BIS issued against Federick Joseph Bergmann Jr. (“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 July 12, 2024. Specifically, Respondent conspired to export various ballistic vests from the United States to Haiti without the required authorization. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Pedro Mascorro - Denial Order; No monetary penalty
BIS issued against Pedro Mascorro (“Respondent”) a Denial Order for a period of 7 years in relation to violations of 18 U.S.C. § 554. The Order went into effect on Respondent’s date of conviction on July 31, 2024. Specifically, Respondent smuggled firearms and ammunition from the United States to Mexico. BIS did not impose any monetary penalty.
- 21 Nov 2025 - James Mwangangi Kiilu - Denial Order; No monetary penalty
BIS issued against James Mwangangi Kiilu (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 554. The Order went into effect on Respondent’s date of conviction on February 1, 2024. Specifically, Respondent exported firearms from the United States to Mexico. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Kevin Uriel Garza - Denial Order; No monetary penalty
BIS issued against Kevin Uriel Garza (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 554. The Order went into effect on Respondent’s date of conviction on September 12, 2024. Specifically, Respondent received, concealed, bought, sold and facilitated the transportation and sale of ammunition prior to exportation from the United States, knowing that such items were intended for export form the United States without the required authorization. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Miguel Ocura-Arenas - Denial Order; No monetary penalty
BIS issued against Miguel Ocura-Arenas (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 554. The Order went into effect on Respondent’s date of conviction on August 25, 2024. Specifically, Respondent facilitated the transportation and concealment of firearms and ammunition prior to exportation from the United States to Mexico, knowing that such items were intended for exportation from the United States without the required authorization. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Mohamed Daoud Ghacham - Denial Order; No monetary penalty
BIS issued against Mohamed Daoud Ghacham (“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 18, 2024. Specifically, Respondent conspired with others to make out and pass forged and fraudulent invoices and other documents and papers through a United States customhouse. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Ghacham, Inc. - Denial Order; No monetary penalty
BIS issued against Ghacham, Inc. (“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 28, 2024. Specifically, Respondent conspired with others to make out and pass forged and fraudulent invoices and other documents and papers through a United States customhouse. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Sadir Arvizu Velazquez - Denial Order; No monetary penalty
BIS issued against Sadir Arvizu Velazquez (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 554. The Order went into effect on Respondent’s date of conviction on April 3, 2024. Specifically, Respondent attempted to export firearms from the United States to Mexico without the required authorization. BIS did not impose any monetary penalty.
- 21 Nov 2025 - Varun Maharajh - Denial Order; No monetary penalty
BIS issued against Varun Maharajh (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 554. The Order went into effect on Respondent’s date of conviction on September 4, 2024. Specifically, Respondent attempted to export and send firearms and ammunition from the United States to the United Kingdom and Trinidad and Tobago without the required authorization. BIS did not impose any monetary penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 21 Nov 2025 (EU):
The European Commission (the "Commission") issued new Russia sanctions FAQs in respect of the "import ban on liquefied natural gas (LNG)", pursuant to Article 3ra of Council Regulation (EU) No. 833/2014 ("Regulation 833").
- 21 Nov 2025 (EU):
The European Commission (the "Commission") updated its Russia sanctions FAQs in respect of restrictions related to "State-owned Enterprises", pursuant to Article 5aa of Council Regulation (EU) No. 833/2014 ("Regulation 833").
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