2026 Trade Compliance: $250 Million Reasons to Pay Attention

21 Apr, 2026 |

2:00 PM EST

60mins

Virtual event

1.0 Credits

Tariffs are at their highest levels since the 1930s. Sanctions programs targeting Russia, Belarus, and China continue to expand. And enforcement actions are reaching into the hundreds of millions of dollars—with instances of single penalties exceeding $250 million. Missing a regulatory shift can now carry nine-figure consequences.

This Continuing Legal Education (CLE) covers the key export control, import, and sanctions frameworks driving record enforcement actions and news headlines. We'll discuss examples such as the Supreme Court's recent ruling on tariff authority to the landmark penalties against Applied Materials, Boeing, and RTX. The common thread? Agencies aren't just enforcing rules, they're making examples. Finally, we'll dig into the diligence strategies and compliance program updates that in-house counsel should prioritize as agencies ramp up enforcement amid a regulatory landscape that continues to shift.

This CLE is eligible for credit in all 50 states and free to register.

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CLE Agenda

Regulatory Foundations

ITAR and EAR licensing, recordkeeping, and registration requirements
HTS classification, duty calculation, and import compliance obligations
OFAC sanctions programs: comprehensive vs. selective, secondary sanctions, and prohibited transactions

Key Focus Areas

Russia & Belarus: sanctions, professional services restrictions, and available general licenses
Hong Kong: arms embargo, DDTC notification requirements, and license exception restrictions
Military end-use/end-user rules and current MEU countries
Foreign national employees: deemed export rules and managing access to controlled data

Tariffs

Current rates under IEEPA and the Supreme Court's ruling on presidential tariff authority
Alternative legal authorities and trade agreement concessions
Mitigation strategies and retaliatory measures

Diligence & Enforcement

Restricted party screening, beneficial ownership research, and end-use verification
Recent OFAC actions: IMG Academy, Exodus Movement, IPI Partners, Interactive Brokers
State Department penalties: Precision Castparts, Boeing, RTX
Commerce/BIS penalties: Cadence Design Systems, Applied Materials

Trends & Takeaways

Continued enforcement focus on Russia and China
Growing use of Withhold Release Orders and multilateral engagement
Human rights and corruption as emerging sanctions drivers
Key elements of a defensible compliance program

Presenters

Heather Sears

Compliance Counsel

Axiom

Heather Sears is a senior trade compliance attorney with more than 24 years of experience advising global businesses on export controls, sanctions, customs, and anti-corruption laws. She has counseled companies across the defense, technology, telecommunications, and life sciences sectors on compliance with the ITAR, EAR, OFAC regulations, and CBP requirements. Her work spans the full lifecycle of trade compliance—from building and overhauling compliance programs to conducting investigations, managing voluntary disclosures, and supporting remediation efforts. Heather has also served as a member of the State Department's Defense Trade Advisory Group (DTAG), where she co-chaired subgroups that developed compliance guidelines and regulatory recommendations for the Directorate of Defense Trade Controls. She holds a JD from the University of Baltimore and an MBA and MS from the University of Maryland.

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2026 Trade Compliance: $250 Million Reasons to Pay Attention

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CLE Agenda

Presenters