USA - Nationwide: An International Trade: Export Controls & Economic Sanctions: Highly Regarded Overview

Trade in Transition: 2026 Export Trends

In 2026, export markets are operating within a significantly more complex environment than before. This is due to geopolitical conflict, evolving regulatory frameworks, and rapid technological advancement in semiconductors and AI. Early data has already introduced substantial volatility into global energy markets and international trade flows.

At the same time, top US export producers highlight the growing importance of certain industries, which include oil and gas, semiconductors, pharmaceuticals and aerospace components. They are not only economically significant but also a major concern within national security policy. As a result, regulations from different US agencies – including the Bureau of Industry and Security (BIS) and the Office of Foreign Assets Control (OFAC) – enforcement priorities and legislative action increasingly influence export activity.

Taken together, these developments indicate that US export performance in 2026 cannot be understood solely through trends in export data. Instead, it must be analyzed within the broader context of shifting regulatory priorities, geopolitical pressures and trends within certain sectors. This overview ties together recent export data, developments in semiconductor and drone export controls, evolving OFAC sanctions policies, and the increasing importance of compliance management in a global context.

General Trends and Export Data

The most recent available data does not consider the effects of the conflict that began in Iran at the end of February 2026. As of 2 April 2026, the US Census Bureau and the US Bureau of Economic Analysis report that the USA exported USD314.8 billion worth of goods and services in February 2026. Trends continue to shift in a volatile global environment, and exporters face uncertainty throughout global supply chains.

Semiconductor Trends

While the USA exports a wide range of products and services, semiconductors are perhaps one of the most significant export markets, both in terms of their growth over the past few years and their importance in the global AI race. Since 2022, the US chip industry has grown tremendously; subsequently, so has its export market. In 2024, according to the Semiconductor Industry Association (SIA), the USA was the eighth-largest semiconductor exporter in the world. By 2032, SIA expects that the USA will manufacture 28% of advanced chips worldwide, largely due to the 2022 CHIPS Act.

Although semiconductor production has boosted the US economy and created thousands of jobs, it has also led to growing unease that current export controls may be insufficient to protect advanced chips manufactured in the USA. Consequently, semiconductor export controls have been at the forefront of US export trends in 2026.

A New York Times opinion piece by guest essayist Sebastian Mallaby, a senior fellow at the Council on Foreign Relations, describes how some developers are avoiding US export controls. For example, a Chinese developer might go to a neighboring country and train their AI models at a data center that utilizes US-origin technology – with little to no detection. It is unclear what specific data centers in Southeast Asia these developers use, but the region has become a known hotspot for data centers in the last few years.

Political leaders across several US agencies have expressed concerns surrounding illegal semiconductor exports. Assistant Secretary for Export Enforcement David Peters recently testified that chip smuggling was among the agency’s top enforcement priorities. Likewise, Secretary of Commerce Jeffrey Kessler has voiced concerns about chip smuggling.

Trepidations around illegal export practices surrounding semiconductors have grown among members of Congress. On April 22nd, the House Committee on Foreign Affairs advanced more than 20 export-control-related bills. While not all of them had to do with semiconductors, semiconductors were a common theme.

Congressional bills such as H.R.8283 – Deterring American AI Model Theft Act of 2026 seek to target model extraction (ie, the practices outlined in Mallaby’s article.) This bill orders the Secretary of Commerce to coordinate with other agencies to determine whether entities involved in model extraction should be placed on the BIS Entity List.

The director of the White House Office of Science and Technology Policy released a memo highlighting similar concerns surrounding foreign AI model extraction. He noted that the administration will coordinate with US companies in the private sector.

Another bill called the Chip Security Act would require location verification on advanced chips that are controlled for export and promote studies concerning chip security mechanisms.

Interestingly, despite the alarm bells from US officials, the administration has taken steps that could increase the sale of semiconductors to China and some Middle Eastern countries. For instance, on January 13th, a new BIS rule stated that the agency will review export licenses for semiconductors such as Nvidia H200, AMD MI325X and similar chips destined for China on a case-by-case basis. Previously, such transactions had been subject to a general presumption of denial.

Still, most officials appear to support increased enforcement action for export violations. Earlier this year, Congress approved a USD235 million fiscal year budget for BIS, around USD44 million more than the previous year.

Of the six publicly charging letters released by BIS between January and April 2026, all involved export violations to China. Four of the six charges involved semiconductors.

One such charge involved Applied Materials Inc, a semiconductor manufacturing equipment company based in California, and its subsidiary based in South Korea (Applied Materials). BIS found that Applied Materials re-exported or attempted to re-export controlled semiconductor equipment without the required export licenses on 56 occasions. Applied Materials settled with BIS for USD252,500,300, one of the largest fines BIS has ever issued, and the maximum allowed by the Export Control Reform Act.

Drone Export Trends and Changes

While the semiconductor export market is growing and facing new challenges, US officials hope to bolster the USA’s industrial defense market. Drone dominance has been a focus for the current administration. Consequently, the administration has pursued strategies to increase domestic drone production and has eased export controls on certain drones.

In January, BIS eased export controls on some less sensitive commercial UAVs to certain export destinations. In the same rule, BIS declared that certain more capable non-military UAVs, including those used for long-range cargo delivery and agricultural spraying, could now be eligible for export or re-export to certain destinations under an export license exception.

OFAC Sanctions

Another significant part of 2026 export trends includes OFAC sanctions and their implementation amidst geopolitical conflict.

In total, OFAC has issued 16 general licenses involving Venezuela since the beginning of this year. Many of these licenses concern transactions relating to oil, minerals, energy and finance.

Additionally, after the Iran conflict began, OFAC authorized specific transactions with Russia and Iran concerning oil and energy products. OFAC granted general temporary licenses for the sale and delivery of Iranian oil already at sea and for Russian oil under similar conditions.

Conclusion

In 2026, a next-level export management strategy has become a daily necessity for our clients.

The Iran conflict is already influencing global demand patterns. Simultaneously, the semiconductor industry illustrates how export growth can coexist with heightened regulatory scrutiny. Other sectors, such as drone manufacturing, demonstrate a targeted effort to balance national security concerns with economic growth.

Regulatory changes that ease certain export restrictions emphasize an attempt to support US industry while protecting US products and technology. Similarly, OFAC’s use of general licenses highlights a change in the way sanctions are used amidst geopolitical conflict and economic pressure.

Ultimately, the flow of commerce will depend not only on market demands but also on the ability of exporters to adapt. Wherever located, exporters who prioritize compliance, flexibility and strategic awareness will be best positioned to operate effectively in 2026 and beyond.