Reid Whitten

Reid Whitten

Sheppard Mullin Richter & Hampton LLP

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The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction

On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions...more

4/2/2015 - Commerzbank Corporate Fines DOJ Extraterritoriality Rules Forfeiture Iran Sanctions Jurisdiction Non-Judicial Settlement Agreements Sanctions Sudan

Read the Directions Carefully Before Playing: State Department Releases Military Drone Export Guidance

The United States has a responsibility, or so the State Department tells us, to ensure the sales and exports of Unmanned Aerial Systems (UAS) are consistent with U.S. national security interests, U.S. policy, and even U.S....more

3/6/2015

Change Your Entire Energy Export Policy Using This One Weird Trick! BIS “Clarifies” Short Supply Controls to Make Oil Exporting...

On December 30 the Commerce Department shifted the oil export landscape as it had existed for 40 years, with only a little administrative sleight-of-hand. ...more

1/16/2015 - BIS Export Controls Exports Guidance Update Oil & Gas U.S. Commerce Department

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

Military Electronics Export Reform: Let the Chips Fall Where They May

Every time there is a new round of reforms under the President’s Export Control Reform initiative, we hear the same advice: - Controls on certain items are eliminated or reduced (which creates new opportunities for...more

12/8/2014

Bulletin: Commerce Department Statistics on the First Year of Export Control Reform

Here is a summary of export data for the first year after the initial implementation of ECR: There have been over 61,000 shipments of 600 series items since October 2013. The 600 series exports are valued at...more

10/17/2014 - Export Controls Exports Trade Policy U.S. Commerce Department

ECR Episode IX: The Export Control Reform Turns One – What are Your Plans for the Big Celebration?

The Year Mark - Apparently, it is now fashionable among my peers to host elaborate parties in honor of the first birthdays of their children. I have attended a number of these fêtes, and been impressed to just what...more

10/14/2014 - BIS EAR Export Controls ITAR

Shelter from the Coming Storm: Anti-Corruption Compliance in European Public Procurement

A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four...more

7/17/2014 - Anti-Corruption Enforcement EU European Commission Transparency

BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of...more

6/16/2014 - Anti-Money Laundering Bank Secrecy Act Banks BNP Paribas Chief Compliance Officers Enforcement Enforcement Actions Foreign Banks Sanctions

ECR Episode IX – Serving up the Third Round: The Next Wave of Export Control Reform Takes Effect on July 1, 2014

In the country pubs of Ireland, it has long been the practice of the barkeep to “stand the third round” for good customers, meaning to offer the third drink for free. The practice makes sense both as customer appreciation...more

6/13/2014 - Export Controls Exports Imports ITAR Trade Policy US Munitions List

ECR Series Episode VII: Livin’ in a Materials World – Changes to USML Category XIII

If you manufacture or export Auxiliary Military Equipment controlled under Category XIII of the U.S. Munitions List, you may rightly consider the category number unlucky. The current scope of Category XIII controls is broad...more

11/18/2013 - Export Controls Exports ITAR US Munitions List

Export Control Reform Series Episode II: The First Change – Reevaluating your ITAR Aircraft Parts

In Episode I: The Basics we noted that U.S. Export Control Reform may be causing confusion and consternation among those who will have to take the first theoretical rule changes and apply them in real and practical...more

8/7/2013 - Aircraft Compliance Export Controls Exports ITAR US Munitions List

What Export Control Reform Means for You: Let Us Cl-EAR Up Changes to the ITAR – Episode I: The Basics – Five Points to Remember...

The first major wave of the much-discussed U.S. Export Control Reform measures will break on October 15, 2013 as the first round of rule changes take effect. While many in the affected industries expect that the October...more

7/12/2013 - Export Administration Regulations Export Controls Exports ITAR

$8 Million Penalty for Weak ITAR Compliance: How the Price of Maintenance Beats the Cost of Repair

On April, 30, 2013, Raytheon Company, a major military electronics and weapons manufacturer, agreed with the U.S. Department of State to pay $8 million in civil penalties and remedial expenditures to settle alleged violations...more

5/8/2013 - Compliance DTCC ITAR Maintenance Penalties Repairs

Gentlemen, Start Your Engines: The Race for Riches in U.S.–EU Trade Begins with a Mandate from the European Commission

Agreements to free up the flow of trade between countries or regions are aimed to increase economic activity and wealth on both sides. The EU and United States, however, already make up 40% of global economic output and the...more

4/3/2013 - EU European Commission Exports Imports Tariffs

Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more

4/3/2013 - Barack Obama Commerce Control List Compliance Executive Orders Export Administration Regulations Exports ITAR US Munitions List

Is China Getting Serious or Redirecting Responsibility? New guidance on Chinese Anti-Bribery Enforcement

For years, a significant number of Foreign Corrupt Practices Act (FCPA) enforcement actions have focused on or involved the People’s Republic of China (PRC), Chinese subsidiaries, or Chinese officials. It is hard to avoid...more

2/21/2013 - Anti-Bribery China Corruption Perceptions Index Enforcement FCPA

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