As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
Department of the Treasury – OFAC
The Office of Foreign Assets Control (OFAC) has posted on its website that it will only process applications and queries that satisfy an appropriate exception (e.g., to ensure the safety of human life or the protection of property). OFAC will hold all other licensing-related submissions until Congress restores appropriations. However, OFAC will continue to administer the Specially Designated Nationals (SDN) list and enforce economic and trade sanctions as directed by the Secretary of the Treasury, and will implement and administer new sanctions on foreign countries or targeted individuals or entities through newly issued Executive Orders (EO). Further, administration and enforcement of economic and trade sanctions, and monitoring and dissemination of terrorism and financial intelligence reporting will continue.
Department of State – DDTC
The Director of Defense Trade Controls (DDTC) has posted on its website that services “are significantly curtailed.” The Defense Export Control and Compliance System (DECCS) submissions for registrations, licenses, Advisory Opinions, and Commodity Jurisdiction determinations is currently not available. Requests currently in process at DDTC as of September 30th, 2025, will remain in that status; however, further review of actions that do not fall under “excepted” functions will be delayed until after the restoration of funding and resumption of operations. “Excepted” functions that may be continued during a lapse in appropriations include those necessary to respond to emergencies involving the safety of human life or the protection of property, and those necessary for activities essential to national security, including the conduct of foreign affairs essential to national security.
Department of Commerce – BIS
The Bureau of Industry and Security (BIS) has indicated that it will only review and process emergency license applications and draft regulations related to the support of United States and allied military activity and protection of U.S. property and human life. Its headquarters and field offices will continue to monitoring open investigations, opening new cases, and responding to all contingencies, including actions to prevent or stop illegal exports that might arise during a lapse of appropriations. This includes continuing export enforcement, ongoing conduct of criminal investigations and prosecutions, and coordination with other law enforcement and intelligence agencies in furtherance of national security.
Department of Homeland Security – CBP
U.S. Customs and Border Protection (CBP) has confirmed that it is fully operational and, since its officers are classified “essential personnel,” all ports of entry are fully staffed and clearing cargo. Cargo examinations, agricultural inspections, and tariff/revenue functions will continue. Cargo Systems Messaging Service (CSMS) notices will continue to be issued to the public, and the Automated Commercial Environment (ACE) system continues to be operational.