Good Practice

Turning Enforcement into Advantage: Applying Lessons Learned

Issue 60
January 2026

Author
Steven BrothertonElizabeth ShinglerMadeline HorningTodd Willis
+ About author

Steven Brotherton (San Francisco) is a Principal in the Global Export Controls & Sanctions practice of KPMG LLP and leader of the service line. sbrotherton@kpmg.com

Elizabeth Shingler (Richmond) is a Senior Manager in the Global Export Controls and Sanctions practice of KPMG LLP. eshingler@kpmg.com

Madeline Horning is an Associate at KPMG LLP. mhorning@KPMG.com

Todd Willis is a director in the Trade & Customs Services practice of KPMG LLP and leader of the Global Export Controls & Sanctions service line; he is based in Chicago.

U.S. regulators have sharply increased penalties for export controls violations in the past two years. While enforcement actions serve as warnings, companies should also look to these cases as lessons learned in export compliance. These enforcement actions highlight common issues and understanding these trends can help exporters prevent future violations, strengthen compliance programs, and reduce risk. Misclassification of Jurisdiction / Classification Recent enforcement actions reveal that mis...

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