If your company ships a part, licenses software, or wires money across a border, U.S. sanctions and export controls apply to you. That is true whether you are a Tulsa aerospace supplier, an oilfield equipment maker in western Oklahoma, a university lab, or a family business that just landed its first foreign distributor. Reams Law advises businesses in California, Oklahoma, Texas and Missouri on these rules.

These laws are no longer a concern only for defense contractors and big banks. Since 2022, the federal government has steadily widened the restrictions on Russia, Belarus, China, Iran and others. It has also focused enforcement on companies whose products end up with prohibited parties through middlemen in third countries.

Why sanctions and export controls matter now

The rules change constantly. The Treasury Department’s Office of Foreign Assets Control (OFAC) issues new designations and general licenses most weeks. In 2026 alone it has repeatedly issued and amended Russia-related licenses tied to oil, Lukoil and Rosneft.

The Commerce Department’s Bureau of Industry and Security (BIS) now requires a license for essentially every item on its Commerce Control List going to Russia or Belarus, and many ordinary commercial items as well. A new BIS “Affiliates Rule” would extend Entity List restrictions to any company owned 50 percent or more by a listed party. That rule was suspended for one year and is scheduled to return on November 10, 2026, unless BIS extends the suspension.

The stakes are serious. OFAC civil penalties can reach $377,700 per violation or twice the value of the transaction, whichever is greater. OFAC applies strict liability, so a company can be penalized even if it did not know it was dealing with a sanctioned party. Willful violations can bring criminal charges.

China, Hong Kong and Taiwan

China is now the main focus of U.S. export-control enforcement, and the rules shift often.

• Chips, AI and advanced technology. Advanced semiconductors, chipmaking equipment, and supercomputing items need a license for China, Hong Kong and Macau. In January 2026 BIS moved certain advanced chips to case-by-case review, but a license is still required. BIS guidance in May 2026 also requires a license for advanced computing items shipped to companies headquartered in China, wherever the buyer is located.
• Restricted Chinese companies. Hundreds of Chinese companies are on the Entity List and Military End-User List. If the Affiliates Rule returns, their majority-owned subsidiaries will be restricted too, even if not named.
• Investing in China. U.S. persons who invest in Chinese companies working on semiconductors, AI or quantum computing may be prohibited from the deal or required to notify Treasury. Treasury announced its first penalty under this program in October 2026, and proposed rules that would expand it to biotechnology. Public comments are due December 7, 2026.
• Imports. Goods made wholly or partly in Xinjiang are presumed barred from U.S. import under the Uyghur Forced Labor Prevention Act. Products with Chinese components may also face other import restrictions.
• China’s own rules. China maintains its own export-control list and counter-sanctions laws. Companies doing business in both markets can find U.S. and Chinese requirements pulling in opposite directions.

Taiwan is not sanctioned, and most U.S. trade with Taiwan flows freely. But Taiwan sits at the center of the global chip supply chain, so U.S. rules can reach Taiwanese-made products made with U.S. technology, and regulators watch for diversion through Taiwan-based intermediaries. Taiwan also runs its own export-control regime. In June 2025 it added Huawei, SMIC and 599 other entities to its Strategic High-Tech Commodities Entity List, so Taiwanese companies need government approval to export to them. If you buy from, sell to, or partner with Taiwanese companies, both sets of rules can affect your deal.

Reams Law advises on China, Hong Kong and Taiwan trade, investment and supply-chain issues alongside our Russia-related work. Reams Law also has Chinese speakers available for consultations.

Who needs a sanctions or export-control review

You may need a sanctions or export-control review if your business:

• Sells products, parts, or software to customers outside the United States, or to U.S. customers who resell abroad
• Receives orders from new distributors in transshipment hubs such as the UAE, Turkey, Central Asia or the Caucasus
• Makes or handles electronics, machinery, oilfield equipment, aircraft parts, chemicals, or encryption software
• Employs foreign nationals who access controlled technology (a “deemed export”)
• Buys from, sells to, or invests in companies in China, Hong Kong or Taiwan, or any company with foreign owners, customers or suppliers
• Has discovered a shipment or payment that may have violated the rules

How Reams Law helps with sanctions and export controls

Reams Law represents businesses in California, Oklahoma, Texas and Missouri on sanctions and export controls matters, including:

• Risk assessments. We review your products, customers, markets and ownership structure, and identify where your exposure lies.
• Export classification. We help determine how your items are controlled under the Export Administration Regulations, and whether a license is required for a given destination, end user or end use.
• Screening and due diligence. We help you set up screening against the government’s restricted-party lists. We also help you investigate the ownership and red flags behind your customers and distributors.
• Compliance programs. We draft written compliance policies, procedures, contract clauses and recordkeeping systems scaled to the size of your business.
• Licenses. We prepare and pursue license applications with BIS and OFAC when a transaction requires government authorization.
• Transaction reviews and deal diligence. We review specific deals, shipments, and acquisitions before you commit, including whether a U.S. investment in a Chinese company is prohibited or must be reported to Treasury.
• Investigations and voluntary disclosures. If something has gone wrong, we investigate, advise on whether to make a voluntary self-disclosure, and represent you with the agencies.
• Training. We train sales, shipping, and finance staff to spot red flags before an order ships.

Why Reams Law

C. Austin Reams is licensed to practice law in California, Oklahoma, Texas and Missouri and has practiced for more than 20 years. Before law school, he worked at Los Alamos National Laboratory supporting U.S. nuclear nonproliferation programs, and at the International Atomic Energy Agency in Vienna analyzing illicit trafficking of nuclear and radioactive materials. He holds a master’s degree in international relations from Boston University, studied in Moscow, and speaks, reads and understands Russian.

That background matters in practice. Many diversion schemes involve Russian-language documents, websites, and corporate records that clients cannot otherwise read. Austin can review them directly. For clients doing business in China, Hong Kong or Taiwan, Reams Law also has Chinese speakers available for consultations.

Getting started

The best time to address export controls is before a problem shipment, not after. If your business is in California, Oklahoma, Texas or Missouri and you are unsure whether your products, customers, or a pending deal raise sanctions or export-control issues, contact Reams Law at (405) 285-6878 or austin@reams.law to schedule a consultation.

This post provides general information and is not legal advice. Reading it does not create an attorney-client relationship. Sanctions and export-control rules change frequently; the information above is current as of November 2026. Consult counsel about your specific situation.