§2M5.1 Evasion of Export Controls: Federal Sentences, Fiscal Year 2024
In fiscal year 2024, a fine was ordered for 8 of the 14 people sentenced under §2M5.1 (57%). Of the 14, 13 (93%) went to prison, with a median prison term of 18 months, and 1 person was convicted after a trial.
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In brief: In fiscal year 2024, a fine was ordered for 8 of the 14 people sentenced under §2M5.1 (57%). Of the 14, 13 (93%) went to prison, with a median prison term of 18 months, and 1 person was convicted after a trial.
This post uses the U.S. Sentencing Commission's records of 14 people sentenced in federal court in fiscal year 2024. Acquittals and dismissals come from a second source, the Federal Judicial Center's records of 753,808 federal defendants whose cases ended in fiscal years 2016 to 2025. It is part of the Federal Prosecution Analysis series, which builds on Military Moves Toward Sentencing Guidelines to Mirror the Federal System. How the numbers were built: How the Federal Comparison Data Was Built.
Fines Ordered for 8 of 14 People
The U.S. Sentencing Commission counted 14 people in fiscal year 2024 whose primary guideline was §2M5.1. The guideline is titled "Evasion of Export Controls; Financial Transactions with Countries Supporting International Terrorism" in the Guidelines Manual.
A fine was ordered for 8 of them (57%), and restitution for 1 (7%). In the same group, 12 people (86%) were ordered to serve supervised release after prison, with a median term of 36 months.
The fine share in this year can be compared with fiscal year 2023, when it was 36%, and with fiscal year 2022, when it was 24%. The 2024 share is higher than both of those.
Prison Terms and the One Trial
Prison went to 13 of the 14 (93%). Probation only went to 0 (0%). The median prison term was 18 months. A quarter received 24 months or more, and a quarter received 6 months or less.
13 people pleaded guilty (93%), and 1 was convicted after a trial. Guilty pleas carried a median prison term of 15 months. The trial figure was 24 months, and it rests on that 1 person, so it is not an average of anything.
Every guilty plea (100%) included a written plea agreement. A mandatory minimum prison term applied to 0 of the 14 people with that information recorded (0%).
Where Sentences Fell Against the Range
One sentence (7%) was within the guideline range. 8 (57%) were below the range at the government's request, and 5 (36%) were below the range without a government request. None (0%) was above it.
The within-range share was 21% in fiscal year 2023 and 18% in fiscal year 2025. For all guidelines in fiscal year 2024, it was 46%.
Criminal History
All of the group (100%) were in the lowest criminal history category (category I), and 0% were in the highest (VI). Court-martial records have no criminal history field.
The Wider Series and All Federal Cases
Over fiscal years 2016 to 2025, 162 people were sentenced under §2M5.1. Of them, 84% were sent to prison, the median prison term was 18.3 months, and 98% pleaded guilty. The 2024 median is about the same as that.
In fiscal year 2023, the median was 21 months. In fiscal year 2025, it was 24 months. Everyone sentenced in federal court in fiscal year 2024, under every guideline, totaled 61,678 people, with a median prison term of 30 months.
Fiscal year 2024 ran from October 1, 2023 to September 30, 2024. The numbers cover only people who were convicted and sentenced, and prison terms are those imposed, not time served.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 11 | 14 months | 100% |
| 2017 | 19 | 16.5 months | 95% |
| 2018 | 17 | 24 months | 100% |
| 2019 | 14 | 22.4 months | 100% |
| 2020 | 16 | 18.7 months | 100% |
| 2021 | 22 | 12.9 months | 95% |
| 2022 | 17 | 15 months | 100% |
| 2023 | 14 | 21 months | 100% |
| 2024 | 14 | 18 months | 93% |
| 2025 | 18 | 24 months | 100% |
What the Records Do Not Say
The records do not explain why fines were ordered more often in this year, and they do not describe individual cases. The approved crosswalk lists no close court-martial counterpart here, so this post stands on the federal numbers alone.
How We Counted
Everyone sentenced in federal court in fiscal year 2024 whose primary sentencing guideline was §2M5.1 (14), U.S. Sentencing Commission individual data files. The primary guideline is the one that set the offense level for the most serious count.
Federal fiscal years run from October 1 to September 30. No person, judge, or lawyer is identified in any of these records.
What to Keep in Mind
No parole in federal prison; credit for good conduct. Federal prison has no parole for crimes committed on or after November 1, 1987. A federal prisoner can earn up to 54 days of good conduct credit for each year of the sentence the judge imposed, which is about 15%. Some federal prisoners can also earn First Step Act time credits, but many offenses make a person ineligible. The numbers in this post are the sentences judges imposed, not the time people actually served.
Federal supervised release. Most federal prison sentences are followed by a term of supervised release that the judge sets as part of the sentence. A person who violates it can be sent back to prison. A court-martial cannot sentence anyone to supervision after release. Military parole and mandatory supervised release are decided later by a board, not by the judge at trial.
Who decides the sentence, and under what rules. Federal judges sentence every federal case. They must calculate the Sentencing Guidelines range, which is advisory, and must impose any mandatory minimum the statute requires unless an exception applies. In courts-martial, the accused could choose sentencing by members until the rules changed. For cases in which every guilty finding is for an offense committed after December 27, 2023, a military judge sentences alone, within sentencing parameters. Courts-martial tried in 2024 and later include both old-rule and new-rule cases, and the data cannot tell them apart.
Time periods. Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.
How life sentences and "time served" are counted. In the federal numbers, a life sentence is counted as 470 months, and any other sentence longer than 470 months is counted as just under 470 months. A sentence of "time served" is counted as one day (0.03 months). Averages are affected by these rules; medians much less.
Related Analysis
- Military Moves Toward Sentencing Guidelines to Mirror the Federal System (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- §2M5.1 Evasion of Export Controls: Federal Sentences, FY2016–2025 (overview)
- §2M5.1 Evasion of Export Controls: Federal Sentences, Fiscal Year 2023 (previous or next fiscal year)
- §2M5.1 Evasion of Export Controls: Federal Sentences, Fiscal Year 2025 (previous or next fiscal year)
- How Often Federal Judges Sentence Outside the Guideline Range
- Mandatory Minimums: How Many Federal Sentences Are Set by Congress
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (source)
About the author. Jocelyn C. Stewart is a retired Army JAG with more than 24 years of trying courts-martial and more than 200 jury trials. She hosts Where All The Bodies Are Buried and runs the Law Office of Jocelyn C. Stewart. This analysis is for education and information only. It is not legal advice, and every case is different.