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The Month in International Trade – December 2025

Client Alert | 11 min read | 01.07.26

Top Trade Developments

Crowell Speaks

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Anand Sithian or Simeon Yerokun or any member of the International Trade Group.

Top Trade Developments

FinCEN Announces Enforcement Initiative for MSBs Along the Southwest Border

On December 22, 2025, FinCEN announced an ongoing enforcement initiative against more than 100 money services businesses (“MSBs”) operating along the Southwest U.S. border. FinCEN says that it reviewed over one million currency transaction reports (“CTRs”) and 87,000 suspicious activity reports (“SARs”) using new data processing techniques to identify potential Bank Secrecy Act (“BSA”) compliance concerns with MSBs there. The agency says this resulted in six FinCEN Notices of Investigation, “dozens” of referrals to the IRS, and 50 compliance outreach letters. An accompanying video from Treasury Secretary Scott Bessent suggests that the initiative is intended to “stop terrorist cartels, drug traffickers, and human smugglers” and to “root out potential cartel-related money laundering from the U.S. financial system.”

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For more information, contact: Carlton Greene and Erik Woodhouse

An ITAR-ly Critical Reminder of Cybersecurity Requirements: DOJ Settles with Swiss Automation, Inc.

On December 5, 2025, the Department of Justice (DOJ) announced that Swiss Automation Inc., an Illinois-based precision machining company, agreed to pay $421,234 to resolve allegations that it violated the False Claims Act (FCA) by inadequately protecting technical drawings for parts delivered to Department of Defense (DoD) prime contractors.  This settlement reflects DOJ's persistent emphasis on cybersecurity compliance across all levels of the defense industrial base, reaching beyond prime contractors to encompass subcontractors and smaller suppliers.  The settlement is also a reminder to all contractors not to overlook the often confusing relationship between Controlled Unclassified Information (CUI) and export-controlled information.

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For more information, contact: Kate Growley, Michael Gruden, Nkechi Kanu, Brian Tully McLaughlin, Scott Wise, Jessica Chao

Record-Setting False Claims Act Settlement Highlights DOJ Commitment to Customs

On December 19, 2025, the Department of Justice (DOJ) announced a $54.4 million settlement with Ceratizit USA, LLC, a distributor of tungsten carbide products, resolving allegations that the company violated the False Claims Act (FCA) by evading customs duties on products imported from China. This settlement is believed to be the largest ever customs-related FCA resolution, and this high-water mark underscores the government’s heightened enforcement focus on tariff evasion.

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For more information, contact: Jason Crawford, Sharmistha Das, Derek Hahn, Zhiwei Chen, William Tucker

Changing EU E-Commerce Rules: New Import Charges Ante Portas

As part of ongoing EU customs reform, the EU’s Council has agreed to remove the duty-free entry of goods valued below €150, formerly known as de minimis, to address the surge in low-value e-commerce shipments. Noticing large volumes imported from foreign marketplaces, the Netherlands proposed in January 2025 to remove simplifications for individual e-commerce packages and promote business-to-business (B2B) trade by placing goods in EU warehouses for further distribution.

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For more information, contact: Vassilis Akritidis, Oleksii Yuzko

Treasury Authorizes Transactions with Belarusian Potash Companies

On December 15, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Belarus General License 13, “Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO.” The general license authorizes all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (“BSR”), involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, Belaruskali OAO, and any entity in which one or more of these entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. However, the general license does not authorize the unblocking of any blocked property, nor does it permit transactions involving any other blocked persons under the BSR beyond the three specifically named entities and their majority-owned subsidiaries.

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For more information, contact: Erik Woodhouse, Sophie Davis, Nate Young

Section 301 Tariffs Announced Against Nicaragua Over Labor and Human Rights Violations

On December 10th, 2025 the US Trade Representative released the results of the Section 301 investigation initiated in December 2024 into Nicaragua’s alleged violations of labor rights, human rights and the rule of law protections. The investigation detailed extensive infringement of labor and human rights in addition to increasingly authoritative restrictions of individual freedoms and liberty. Significantly, the investigation discovered widespread child labor abuses including up to 47 percent of children between the ages of 10 and 14 being forced to perform hazardous work in the mining industry.

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For more information, contact: Simeon Yerokun, Brett Everett

OFAC Fines U.S. Private Equity Fund for Russian Sanctions Violations

On December 2, 2025, OFAC announced an ~$11 million penalty settlement with IPI Partners, LLC (“IPI”), a Chicago-based U.S. private equity fund, to settle its civil liability for 51 potential violations of OFAC’s Russia sanctions. The enforcement action underscores the importance of diligence to guard against potential sanctions violations.  In brief, OFAC found that IPI solicited and received investments from a Russian oligarch, Suleiman Kerimov (“Kerimov”), via his representative, and should’ve blocked those funds following OFAC’s designation of Kerimov to its Specially Designated Nationals and Blocked Persons List (“SDN List”).

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For more information, contact: Caroline Brown, Jeremy Iloulian

Treasury Continues Focus on Cartels: Understanding FinCEN’s Latest Action Restricting Transactions with Certain Mexico-Based Gambling Establishments

On November 13, 2025, the U.S. Department of the Treasury’s (“Treasury’s”) Financial Crimes Enforcement Network (“FinCEN”) issued a finding (“Finding”) and related notice of proposed rulemaking (“Proposed Rule”) pursuant to Section 311 of the USA PATRIOT Act (“Section 311”), targeting ten Mexico-based gambling establishments (“Gambling Establishments”).  FinCEN found transactions involving the Gambling Establishments to constitute a “class of transactions” of “primary money-laundering concern” for purposes of Section 311.  In particular, FinCEN found that the Gambling Establishments ultimately were controlled by a criminal group that used the establishments to facilitate money laundering for the Sinaloa Cartel.

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For more information, contact: Carlton Greene, Erik Woodhouse, Caroline Brown, Anand Sithian, Jackie Schaeffer, Mirenda Gwin

Crowell Speaks

 

“Opening or Closing Gates? Market Access in Global Infrastructure Construction: Between Openness and Strategic Protection,” Inter-Pacific Bar Association (IPBA) Annual Meeting and Conference, New Delhi (February 27, 2026). Speaker: Jeremy Iloulian

“Tariffs & Sanctions in 2026: Practical Guidance for Asia Regional In-House Counsel,” Association of Corporate Counsel, Singapore (January 28, 2026). Speaker: Nicole Simonian, Dan Cannistra, and Scott Wise

“Making International Business Relations Work in Times of Conflict: Perspectives from Practitioners in China, the USA, and Germany,” Institute of Customs and International Trade Law, University of Münster, Virtual (January 17, 2026). Speaker: Jeff Snyder

“Navigating Tariffs, Classification and Origin Determinations: HTS and Country of Origin Essentials and Grey Areas,” Passport to U.S. Customs Compliance Winter Edition, Virtual (January 16, 2026). Speaker: Simeon Yerokun

How to identify and mitigate risks posed by Foreign Terrorist Organizations
December 24, 2025 – Compliance Week
Related Professionals: Michael Atkinson and Caroline Brown

How Tariffs Hit the Brakes on America’s Booming E-Bike Industry
December 9, 2025 – Washington Post
Related Professional: Zhiwei Chen

How Sweeping Sanctions Missed a Business Partner of the Alleged Head of a Major Asian Crime Organization
December 5, 2025 – Organized Crime and Corruption Reporting Project
Related Professional: Clif Burns

“The Rise of Outbound Investment Rules and the Intersection with Sanctions and Export Controls: New Legal and Compliance Considerations Affecting Transactions,” New York Forum on Economic Sanctions, New York (December 4, 2025). Moderator: Caroline Brown

“Cross-Functional Collaboration: Strategies for Clear Communication and Training Across Functions and Jurisdictions,” New York Forum on Economic Sanctions, New York (December 3, 2025). Moderator: Caroline Brown

Contacts

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