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A New Latitude: Charting a Course for Cuba

Today President Barack Obama made a stunning speech announcing steps the United States will take to reduce U.S. sanctions against Cuba. The announcement followed the release of two U.S. citizens held by the Cuban government....more

12/18/2014 - Barack Obama Cuba Foreign Relations

DOJ Issues Opinion, Provides (Some) Comfort on Successor Liability

In a recent Opinion Procedure Release (OPR), Number 14-02, the U.S. Department of Justice expressly limited successor liability for a US company purchasing a non-US company that had paid bribes in the past. In so doing, DOJ...more

12/5/2014 - DOJ Due Diligence Enforcement Guidance FCPA FCPA Guidance FCPA Resource Guide Successor Liability Target Company UK Bribery Act

Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act

On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently...more

10/13/2014 - Anti-Terrorism Act Banks Foreign Banks Hamas OFAC Terrorism Funding U.S. Treasury

What’s New Out There? Highlights from the Federal Register

SBA Proposes to Increase Small Business Size Standards (79 Fed. Reg. 54145; 79 Fed. Reg. 53646) - The U.S. Small Business Administration (“SBA”) proposes to increase small business size standards for: (1) 209...more

9/30/2014 - DFARS DOD FAR Federal Procurement Systems FOIA GSA NASA Satellites SBA Small Business

Who’s a “Foreign Official”? Supreme Court Could Clarify Key FCPA Term

On August 14, 2014, Joel Esquenazi and Carlos Rodriguez filed a Petition for a writ of certiorari in the U.S. Supreme Court seeking clarification of a key term in the Foreign Corrupt Practices Act. Among other arguments,...more

9/19/2014 - Bribery Corruption FCPA Foreign Official Instrumentality SCOTUS

Don’t try this at Home or Abroad: Export Controls and Sanctions Violations Lead to $21 Million in Penalties for Dutch Company...

We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more

7/16/2014 - Aerospace BIS Burma EAR Enforcement Enforcement Actions Exports Fokker Iran Iran Sanctions OFAC Penalties Sanctions Settlement Sudan Trade Policy

Where Two Worlds Collide: The Impact of Sanctions in Space

As we continue to find new ways to look at the implications of the Ukraine-related sanctions introduced by the United States over the past few months, we have shifted our perspective to the extra-terrestrial to focus on the...more

6/13/2014 - Aerospace Foreign Policy Russia Sanctions Ukraine

Spacing Out: BIS Issues Report on Export Controls and the Space Industrial Base

In February 2014, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a report (“Report”) detailing the impact of export controls on the U.S. space industry. Titled the “U.S. Space Industry...more

4/7/2014 - Aerospace BIS Export Controls ITAR

Export Control Reform Series Episode III: Harmonizing EAR Exceptions and ITAR Exemptions

In Episode I and Episode II of this series, we discussed some key points of U.S. Export Control Reform and took you through a step-by-step reclassification analysis of parts and components transitioning from the USML to the...more

8/8/2013 - Classification Export Controls Exports ITAR Licensing Rules Software Technology US Munitions List

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