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# §2M5.1 Evasion of Export Controls: Federal Sentences, Fiscal Year 2025
- URL: https://www.bodiesburied.com/trends/federal-guideline-2m5-1-evasion-of-export-controls-fy2025/
- Published: 2026-11-04T10:57:54.000Z
- Updated: 2026-11-04T10:57:54.000Z
- Description: In fiscal year 2025, 18 people were sentenced under §2M5.1, a count that falls within the 11 to 22 range of the yearly series. Of them, 13 (72%) received a prison term with a median of 24 months (2 years), and 5 (28%) received probation only. All 18 pleaded guilty.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [§2M5.1 Evasion of Export Controls](https://www.bodiesburied.com/trends/federal-guideline-2m5-1-evasion-of-export-controls/) › §2M5.1: FY2025

**In brief:** In fiscal year 2025, 18 people were sentenced under §2M5.1, a count that falls within the 11 to 22 range of the yearly series. Of them, 13 (72%) received a prison term with a median of 24 months (2 years), and 5 (28%) received probation only. All 18 pleaded guilty.

Updated November 4, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025

This post uses the U.S. Sentencing Commission's records of 18 people sentenced in federal court in fiscal year 2025\. 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](https://www.bodiesburied.com/trends/federal/) series, which builds on [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/). How the numbers were built: [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/).

## Fiscal Year 2025 in Brief

The U.S. Sentencing Commission counted 18 people in fiscal year 2025 whose primary guideline was §2M5.1\. The Guidelines Manual titles it "Evasion of Export Controls; Financial Transactions with Countries Supporting International Terrorism." The fiscal year ran from October 1, 2024 to September 30, 2025.

Of the 18, 13 (72%) received a prison term, and 5 (28%) received probation only, with no prison or other confinement. Over fiscal years 2016 to 2025, 84% of people under this guideline were sent to prison, so the 2025 share is lower.

## Prison Terms

The median prison term for the 13 people sent to prison was 24 months. Prison terms of 40 months or more went to a quarter of them, and terms of 12 months or less went to a quarter.

The median for all fiscal years 2016 to 2025 under §2M5.1 was 18.3 months, and the 2025 median is higher. In fiscal year 2024, the median was 18 months. For everyone sentenced in federal court in fiscal year 2025, under every guideline, it was 24 months, across 66,662 people.

Prison terms are those the court imposed, not time served. A mandatory minimum prison term applied to 0 of the 18 people with that information recorded (0%).

## Pleas

All 18 people (100%) pleaded guilty, and 0 were convicted after a trial. Among the guilty pleas, 94% had a written plea agreement, and 6% were straight pleas with no agreement.

The data covers only people who were convicted and sentenced. It does not include acquittals or dismissals.

## Against the Guideline Range

For this measure, the Commission had the information for 17 of the 18 people. Of those 17, 3 (18%) were within the range. 8 (47%) were below the range at the government's request, and 6 (35%) were below the range without a government request. None (0%) was above it.

In fiscal year 2024, the within-range share was 7%. For all guidelines in fiscal year 2025, it was 51%.

## Supervised Release, Fines, and Criminal History

After prison, 12 people (67%) were ordered to serve supervised release, with a median term of 36 months. A fine was ordered for 6 (33%), and restitution for 0 (0%).

About criminal history, 94% of the group were in category I, the lowest, and 0% were in category VI, the highest. Court-martial records have no such field.

## The Series Through Fiscal Year 2025

The table lists each year from 2016 to 2025 for this guideline. Counts have stayed between 11 and 22 people, so each year is a small group.

The records do not say why the share receiving probation differs from year to year. There is no close court-martial counterpart in the approved crosswalk, so only federal numbers are given here.

| 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%           |

### How We Counted

Everyone sentenced in federal court in fiscal year 2025 whose primary sentencing guideline was §2M5.1 (18), 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](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/) (the background article)
- [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) (all federal posts)
- [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/) (sources and method)
- [§2M5.1 Evasion of Export Controls: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2m5-1-evasion-of-export-controls/) (overview)
- [§2M5.1 Evasion of Export Controls: Federal Sentences, Fiscal Year 2024](https://www.bodiesburied.com/trends/federal-guideline-2m5-1-evasion-of-export-controls-fy2024/) (previous or next fiscal year)
- [How Often Federal Judges Sentence Outside the Guideline Range](https://www.bodiesburied.com/trends/federal-sentences-outside-guideline-range/)
- [Mandatory Minimums: How Many Federal Sentences Are Set by Congress](https://www.bodiesburied.com/trends/federal-mandatory-minimum-sentences/)
- [U.S. Sentencing Commission, Individual Offender Datafiles](https://www.ussc.gov/research/datafiles/commission-datafiles?ref=bodiesburied.com) (source)
- [Federal Judicial Center, Integrated Database (criminal defendants)](https://www.fjc.gov/research/idb?ref=bodiesburied.com) (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](https://www.ucmj-defender.com/?ref=bodiesburied.com). This analysis is for education and information only. It is not legal advice, and every case is different.