Think the U.S. Government Only Targets Companies for Violations? Think Again.

Individuals Can Be Debarred Too

Most know that companies that violate the export regulations can be fined, penalized and lose their right to export.  But did you know that not only companies, but individuals can also be held to that same standard?  And that some of these individuals are located right here in the United States?

Earlier this month, the U.S. Department of State published a list of 17 individuals who were debarred because they were convicted of violating the Arms Export Control Act (AECA).  This list also included those people that were conspiring to violate the AECA.

This means that companies cannot engage with these individuals for any work regulated under the ITAR.  It’s important to remember that this goes beyond simply not engaging with those 17 individuals for physical exports, the ITAR also covers manufacturing of ITAR items, receiving ITAR technical data and brokering activities.  It also includes temporary imports into the United States of USML items as well as defense services.  Remember that these individuals are restricted from participating in any activities subject to the ITAR, both directly or indirectly.

The Latest Debarred List

Curious as to who these individuals are?  In order to assist the public with complying with the prohibition, the list is published within the Federal Register and are listed below along with their case number and birth date:

This information is taken directly from the U.S. Department of State’s Federal Register notice, published on August 19, 2025.

• Aldalawi, Rawnd Khaleel — January 11, 2019; Western District of Washington; 2:18-cr-00025; April 1988.
• Chan, Lionel — June 1, 2021; District of Massachusetts; 1:19-cr-10064; August 1983.
• Cox, Michael — May 27, 2021; Western District of Pennsylvania; 2:18-cr-00050; May 1975.
• Duroseau, Jacques Yves Sebastien — March 2, 2021; Eastern District of North Carolina; 4:20-cr-3; May 1986.
• Garza-Solis, Jacobo Javier — November 4, 2020; Southern District of Texas; 7:17-cr-00360; December 1996.
• Issa, Jean Youssef — December 20, 2023; Northern District of Ohio; 1:16-cr-00102; June 1974.
• Koyshman, Josef — February 7, 2020; District of Columbia; 1:19-cr-00267; June 1967.
• Kuznetsov, Vladimir — May 1, 2024; Eastern District of New York; 1:21-cr-00099; October 1961.
• Man, Cho Yan Nathan (a.k.a Nathan Man) — May 19, 2020; District of Columbia; 1:19-cr-00218; December 1985.
• Palomares, Jr., Rafael — May 13, 2021; District of Arizona; 2:19-cr-00089; July 1989.
• Radzi, Muhammad Mohd — June 1, 2021; District of Massachusetts; 1:19-cr-10064; June 1993.
• Rhoomes, Jermaine Craig (a.k.a. Rhoomas, Jermain; a.k.a. Rhoomas, Jermaine Craig; a.k.a. Rhooms, Jermaine; a.k.a. Hall, Craig; a.k.a. Hall, Kreig; a.k.a. Cow) — February 5, 2020; Middle District of Florida; 8:19-cr-00078; April 1973.
• Rincon-Avilez, Gardenia Marlene — December 16, 2024; District of Arizona; 4:18-cr-01141; July 1986.
• Schultz, Korbein — April 28, 2025; Middle District of Tennessee; 3:24-cr-00056; May 1999.
• Senbol, Yuksel — October 31, 2024; Middle District of Florida, 8:23-cr-00384; May 1987.
• Shifrin, Elena (a.k.a Belov, Alexander; a.k.a Ivanov, Lena; a.k.a Gohkman, Elena; a.k.a. Elena Leonidovna Shifrin) — July 23, 2024; Central District of California; 2:21-cr-00259; February 1962.
• Stashchyshyn, Michael — July 20, 2021; Western District of Pennsylvania; 2:18-cr-00050; July 1962.

What This Means for Compliance

One of the key take-aways is that all 17 individuals are in the United States which highlights the importance of screening to ensure your company not only avoids engaging with these individuals from an ITAR export perspective, but that Human Resources, Procurement and any other department screens prior to hire or engagement.  Having a robust screening process supported by procedures ensures compliance with the regulations and avoiding inadvertent export violations.

Remember, the US Government consider export a privilege and not a right.  All of these individuals have been denied their right to export and are debarred as of August 19, 2025.

If news of these recent debarments has you thinking about your own compliance processes, we’re here to support you. Schedule a no-charge consultation with one of our experts to review your procedures and help keep your business in compliance.