Foreign Military Sales restrictions
Foreign Military Sales restrictions are an underappreciated compliance pressure point for Financial & Capital Markets firms, particularly those financing defense-adjacent transactions, underwriting sovereign debt for restricted counterparties, or providing correspondent banking to entities in the U.S. Department of State's FMS review scope. The U.S. Department of the Treasury's Office of Foreign Assets Control and the U.S. Department of State's Directorate of Defense Trade Controls both assert authority here, and their jurisdictions overlap in ways that create real exposure for capital markets desks that assume FMS is a defense-sector problem. Cresthaven is actively monitoring this intersection for regulatory actions, guidance updates, and enforcement patterns as they emerge.
Watch
- DDTC guidance on financial intermediaries facilitating FMS-adjacent transactions
- OFAC secondary sanctions designations affecting sovereign debt underwriting eligibility
- Congressional holds on FMS approvals that could trigger counterparty review obligations
- State Department FMS eligibility list changes touching APAC sovereign borrowers
Recent material activity in Financial & Capital Markets
Active monitoring in place across Financial & Capital Markets. Material developments related to foreign military sales restrictions will appear here as they are published.