Author: Natalia Ermakova, Senior Sanctions Compliance Manager, DP World
Freight forwarders can no longer assume they will be treated as neutral intermediaries. Regulators increasingly expect them to understand what they are handling, who is involved, how the shipment is routed, and whether the surrounding facts point to sanctions evasion, export control exposure, or broader trade compliance risk. For compliance teams, this creates a familiar tension: business wants speed, customers want cargo moved without delay, and intermediaries offer reassurance, while regulators expect forwarders to identify red flags, test information, resolve inconsistencies before cargo moves, and intervene where the risk is unacceptable.
Recent Regulatory Developments
Recent regulatory developments have made sanctions and export controls compliance harder for freight forwarders. The challenge is not only the volume of rules but the speed at which they evolve, their overlap across jurisdictions, their extraterritorial reach, and their tension with local countermeasures or blocking laws.
Russia sanctions continue to grow in complexity. Over the past year, anti-circumvention has moved further to the centre, with stronger focus on diversion routes and third-country re-exports, reinforced by tools such as enhanced due diligence for Common High Priority items, the EU “no Russia” clause, and transaction bans affecting certain Russian ports and airports. This means closer scrutiny of routing, counterparties, and transaction structure.
Syria presents a different challenge. Several jurisdictions have eased parts of their Syria sanctions frameworks, including certain asset freezes and trade in non-dual-use goods, consumer communication devices, and certain aircraft and vessel parts and equipment, but this is not a full reopening. Restrictions remain for military and dual-use items, sanctioned persons, and other higher-risk transactions. A similar, though more limited and conditional, pattern is visible in Venezuela.
The U.S.–China sanctions and export controls environment became more turbulent over the past year. The United States continued tightening controls on advanced computing, semiconductors, aerospace, biotechnology, and other sensitive items, while BIS’s position on affiliate ownership rules, followed by the temporary suspension of that rule, added more complexity. China, meanwhile, continued responding with countermeasures, including the use of the Unreliable Entity List and broader measures aimed at countering foreign extraterritorial restrictions.
Geopolitical shocks further complicate compliance. The recent disruptions around the Strait of Hormuz showed how quickly routing, carriers, and intermediaries can change, increasing the risk of sanctions or export‑control mistakes. In such periods, strong and adaptable compliance controls become even more important, as operational pressure often exposes the very weaknesses regulators focus on.
The result is a more fragmented and unpredictable compliance landscape.
Enforcement in Focus: What Recent Cases Reveal
Recent enforcement actions show that freight forwarders are not viewed as neutral intermediaries. Weak sanctions compliance controls can have serious legal, financial, and commercial consequences, especially where companies apply controls unevenly or overlook red flags and available information.
Urgent business demands at the expense of compliance. Fracht FWO Inc. (“Fracht”), a U.S.-based freight forwarder, agreed to pay more than USD 1.5 million after bypassing internal procedures and entering into a transaction involving a sanctioned Venezuelan carrier and an SDN-listed aircraft. A senior leader signed the deal without sanctions screening and overlooked multiple red flags, including ownership by an OFAC-listed entity, tail-number changes reflecting prior Iranian ownership and Venezuelan registration, and routing showing the aircraft arriving from Venezuela. The case shows how quickly routine failures can erase commercial gains.
Extra services mean extra responsibility. When forwarders act as customs brokers or agents for export and import filings, added revenue brings added obligations. In the U.S., BIS imposed a three-year denial order on package forwarder USGoBuy for 176 failures to file Electronic Export Information (EEI) and other violations; Elite International Transportation paid USD 156,000 for misrepresenting licence status in legacy shipper EEI filings; and P.R.A. World Wide Trading was penalised for 41 EEI filings that understated value. In Europe, French Customs (DNRED) dismantled a broker operation that filed hundreds of false declarations concealing trade flows to Russia and immediately suspended the firm’s authorisation.
Using agents and intermediaries does not transfer responsibility. Delegating part of a shipment to an agent, broker, or intermediary does not insulate the principal forwarder. In the Fracht matter, a broker in Mexico was involved in the transaction, yet liability still rested with the principal forwarder that approved the deal. Where intermediaries reduce visibility, they increase compliance risk rather than absorb it.
Post-acquisition integration failures create immediate sanctions risk. OFAC’s settlements with Key Holding and C.H. Robinson show how quickly inherited weaknesses can become enforcement issues. In Key Holding, a Colombian subsidiary continued managing shipments to Cuba after acquisition by a U.S. parent, bringing the business within the Cuban Assets Control Regulations. OFAC treated the failure to reassess obligations after the acquisition, lack of awareness that the subsidiary had become subject to U.S. Cuba restrictions, and lack of visibility within U.S. management as aggravating factors. In C.H. Robinson, OFAC identified apparent violations involving Iran and Cuba across acquired non-U.S. subsidiaries, including shipments connected to sanctioned jurisdictions, Iranian- or Cuban-origin goods, use of Iranian airlines, and conduct treated as circumvention. In both cases, delayed post-acquisition integration was treated as a compliance failure, not a transitional issue.
Handling only one “clean” leg of the route is not a safe defence. In the C.H. Robinson case, OFAC treated the company’s involvement in one part of the route as sufficient for sanctions liability where the wider shipment involved Cuba or Iran, goods originating in those jurisdictions, or designated carriers. Forwarders cannot focus only on the segment physically handled; the wider movement visible from documents, instructions, or surrounding facts cannot be ignored.
Guidance for the Industry: What Regulators Are Telling Freight Forwarders
Recent guidance reinforces that freight forwarders are not viewed as passive service providers. The December 2023 U.S. “Know Your Cargo” guidance, BIS’s 2024 Freight Forwarder Guidance, and BIS’s updated Don’t Let This Happen to You! materials all stress verification of counterparties, cargo, routing, and red flags. The same direction is visible in UK guidance on countering Russian sanctions evasion and EU anti-circumvention and Common High Priority item due diligence guidance.
Across all these documents, regulators emphasise that forwarders must verify, not assume — especially when information is incomplete or operational conditions are changing. Controls are expected to adapt as quickly as the logistics chain itself.
The Time to Act Is Now
Across jurisdictions and transport modes, regulators are focusing on the full logistics chain. The risk extends beyond direct dealings with sanctioned parties or goods to facilitation, circumvention through third countries or intermediaries, and failures to act on red flags.
These issues — and the practical steps organisations can take to address them — will be at the heart of discussions at the Conferentie over sancties, anticorruptie en exportcontrole in het Midden-Oosten, taking place on 20–21 May 2026 in Dubai, UAE. Bringing together senior compliance professionals, regulators and legal experts from across the region and beyond, the conference will provide actionable insights for freight forwarding and logistics companies navigating this rapidly evolving landscape. If sanctions compliance is part of your professional mandate, this is not a conversation you can afford to miss.
About the Author
Natalia Ermakova is Senior Sanctions Compliance Manager at DP World, where she leads sanctions risk management across the group’s global freight forwarding and logistics operations. She is a speaker at the Sanctions, Anti-Corruption and Export Controls Compliance in the Middle East Conference, 20–21 May 2026, Dubai, UAE.
References/Links
OFAC (Fracht FWO Inc.) Enforcement release (PDF): https://ofac.treasury.gov/media/934596/download?inline
USGoBuy (BIS press release): https://www.bis.gov/press-release/commerce-department-denies-export-privileges-package-forwarding-company-usgobuy
Elite International Transportation (BIS settlement PDF): https://www.bis.gov/media/documents/export-violation/e2031.pdf
P.R.A. World Wide Trading Co. (BIS case PDF): https://www.bis.gov/media/documents/export-violation/e1091.pdf
France (DGDDI/DNRED) https://www.douane.gouv.fr/sites/default/files/2024-05/27/CP-Lutte_contournement_sanctions_prises_encontre_Russie.pdf
Key Holding, LLC: https://ofac.treasury.gov/media/934456/download?inline
C.H. Robinson International, Inc.: https://ofac.treasury.gov/media/933696/download?inline
Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation: https://ofac.treasury.gov/media/932391/download?inline
Freight forwarder guidance and best practices: https://www.bis.gov/learn-support/export-compliance-programs/freight-forwarder-guidance
Don’t Let This Happen to You! Actual Investigations of Export Control and Antiboycott Violations: https://www.bis.gov/media/documents/dlthty-nov-2024-1-7-25
Countering Russian sanctions evasion – guidance for businesses.: https://www.gov.uk/government/publications/countering-russian-sanctions-evasion-and-circumvention/countering-russian-sanctions-evasion-guidance-for-exporters
European Commission Guidance for EU operators: Implementing enhanced due diligence to shield against Russia sanctions circumvention.: https://finance.ec.europa.eu/system/files/2023-12/guidance-eu-operators-russia-sanctions-circumvention_en.pdf