This note distills export controls and sanctions into practical takeaways. In the U.S

This note distills export controls and sanctions into practical takeaways. In the U.S., under OFAC/EAR, civil penalties are the greater of twice the transaction value or the per-violation cap (about $374,474 under EAR as of 2025); criminal exposure can reach up to 20 years’ imprisonment and $1,000,000 per count. In Japan, Foreign Exchange and Foreign Trade Act violations can carry up to 10 years’ imprisonment, corporate fines up to JPY 1 billion, and administrative measures such as export suspension. In practice: (1) screen counterparties, end-use, and end-users against SDN/SSI and the Entity List; treat close matches, shared addresses, and buying agents as red flags. (2) Classify goods: HS for customs, ECCN for controls; determine license needs by destination–use–party. (3) Strengthen KYC: unclear purpose, odd routing, or military/WMD hints demand escalation. (4) Build controls: pre-shipment export holds, recordkeeping, training, reporting lines, and fast legal–trade compliance coordination. (5) Avoid cross-company sharing of price/bid/customer data (antitrust risk). (6) If issues arise, consider Voluntary Self-Disclosure to BIS/OFAC—speed, candor, and cooperation drive mitigation. Rely on BIS, OFAC, and Japan’s METI for current rules. Include reexports, resales, embargoed regions, and evasion schemes in scope, and enforce a “Counterparty × End-use × Item—stop and verify” rule.