Foreign Military Sales restrictions
Foreign Military Sales restrictions sit at the center of Trade and Geopolitical Risk compliance right now, with the U.S. Department of State's Directorate of Defense Trade Controls and the U.S. Department of Commerce Bureau of Industry and Security each asserting overlapping authority over end-use controls, re-transfer approvals, and license conditions that govern defense articles moving through commercial supply chains. The Biden-era FMS policy review tightened third-party transfer conditions on several allied recipients, and those conditions are now live in active Letter of Offer and Acceptance agreements that downstream vendors may not have mapped against their own export authorizations. Compliance teams with defense-adjacent supplier relationships are working now to audit those gaps before they become violations.
Watch
- DDTC end-use monitoring conditions on active LOA agreements with Tier 2 allies
- BIS Entity List additions tied to FMS diversion cases in the Indo-Pacific
- Pending Congressional notifications under Section 36(b) of the Arms Export Control Act
- Re-transfer approval backlogs at State affecting time-sensitive commercial offset contracts
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to foreign military sales restrictions will appear here as they are published.