Susan Kohn Ross

Susan Kohn Ross

Mitchell Silberberg & Knupp LLP

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Latest Publications


DOJ Sets Its Sights on Directors and Officers

Whether publicly traded or privately held, corporate boards have been put on notice – the Department of Justice (Justice or DOJ) is after you! On September 9th, DOJ issued a memo entitled: Individual Accountability for...more

9/30/2015 - Board of Directors C-Suite Executives Chief Compliance Officers Compliance Criminal Prosecution Dodd-Frank DOJ False Claims Act (FCA) FCPA Government Investigations Yates Memorandum

GSP Refunds Clarified

While the oft-rumored Federal Register notice has yet to be seen, Customs and Border Protection (CBP) did publish information about obtaining refunds under the now reinstated Generalized System of Preferences (GSP)....more

8/7/2015 - Customs and Border Protection Exports Generalized Scheme of Preferences GSP Regime Imports Place of Origin Refunds

The Times Are Changing, But Very Slowly

First, we learned relations with Cuba were thawing, and now – on July 14th – there is the nuclear deal with Iran. Many American companies are clambering to make commercial deals with businesses in both countries – but not so...more

7/22/2015 - BIS Cuba EU Foreign Relations International Atomic Energy Agency Iran Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons OFAC U.S. Embassies UN Security Council

Trade Preference Programs Get New Life

On June 29, 2015, the Trade Preferences Extension Act of 2015 became Public Law No. 114-27. As a result, the Generalized System of Preferences (GSP) was extended to December 31, 2017, with retroactive effect to July 31, 2013...more

7/21/2015 - AGOA Customs and Border Protection Exports Generalized Scheme of Preferences Imports International Trade Agreements Liquidation Refunds Trade Preferences Extension Act (TPEA)

Be Careful What You Wish For!

This oft-stated warning is certainly true for those who engage in international trade. For many years, industry has complained to government about different agencies wanting different information at different times in the...more

6/3/2015 - Barack Obama Consumer Product Safety Commission (CPSC) Customs and Border Protection Executive Orders Exports FDA Imports

California Transparency in Supply Chain Act Update

On April 13, 2015, California Attorney General Kamala Harris issued “A Resource Guide” for companies subject to California’s Transparency in the Supply Chain Act (the “Act”). This resource guide was published in conjunction...more

4/22/2015 - Manufacturers Resource Guide Retailers Transparency in Supply Chains Act

President Obama Issues Executive Order Promoting Private Sector Cybersecurity Information Sharing

On Friday, February 13, 2015, President Obama signed an executive order, Promoting Private Sector Cybersecurity Information Sharing (the “EO”), designed to encourage private companies to share information regarding threats to...more

2/18/2015 - Barack Obama Cybersecurity Cybersecurity Framework Executive Orders FOIA Information Sharing NIST Popular Private Sector

Cuba Regulations Change – Round 1

In today’s Federal Register, both the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) published the first revisions to the U.S.’ Cuba economic sanctions. As expected, those changes...more

1/22/2015 - Banking Sector Barack Obama BIS CACR Cuba Embargo Executive Orders Export Controls Exports Imports OFAC Sanctions Telecommunications Trade Policy Trade Relations Travel Permits U.S. Commerce Department U.S. Treasury

Customs Is Again Getting Overly Creative

In late October 2014, Customs and Border Protection (CBP) issued a guidance message in which it laid down new rules regarding post-importation/post-entry claims for duty preference and duty reduction programs – see CSMS re...more

1/8/2015 - Airlines Customs and Border Protection Duty Free Free Trade Agreement Imports NAFTA New Guidance

Obama’s Reboot of U.S.-Cuba Relations: What Does It Mean?

Last Wednesday, President Obama announced the most sweeping changes to U.S.-Cuban relations in half a century, in effect beginning normalization to a relationship fractured by the pressures of the Cold War. Only baby steps...more

12/23/2014 - Barack Obama Cuba Embargo Exports Financial Markets Foreign Relations Imports OFAC Sanctions Telecommunications Travel

Court of Appeals for Federal Circuit (CAFC) Issues Decision In U.S. v. Trek Leather – Corporate Officer Held Liable

Yesterday, the CAFC issued its en banc decision in the U.S. v. Trek Leather case. The Court held the President of the company liable for gross negligence due to his own actions, even if he is an agent of the company....more

9/18/2014 - Agents CAFC Corporate Counsel Corporate Officers Gross Negligence Negligence Personal Liability Vicarious Liability

Tips For Conducting An Internal Investigation

Perhaps your computer system was hacked. Maybe you opened a container to find goods in it that did not belong to you (thank goodness they were not dangerous) or perhaps no goods but evidence people lived in the container...more

4/16/2014 - Corporate Counsel Corporate Governance Internal Investigations

Corporate Officers Becoming Liable for Negligent Acts Is Reconsidered

In July 2013, the decision of the Court of Appeals for the Federal Circuit (CAFC) was announced in United States v. Trek Leather, Inc. and Harish Shadadpuri, Case No. 2011-1527 (July 30, 2013). Harish Shadadpuri (Shadadpuri)...more

3/27/2014 - Board of Directors Corporate Officers Negligence Professional Liability

Cybersecurity Update – How Are You Impacted?

On February 12, 2014, the Obama Administration released the long-awaited Cybersecurity Framework: “a voluntary how-to guide for organizations in the critical infrastructure community to enhance their cybersecurity” (the...more

3/3/2014 - Critical Infrastructure Sectors Cybersecurity Cybersecurity Framework NIST

Did You Do Enough to Protect Your Trade Secrets?

On January 21, 2014, Mozaffar Khazaee, a naturalized American who maintained dual citizenship with his native Iran, was indicted in Connecticut on two counts of interstate transportation of stolen property, which carries with...more

1/30/2014 - Confidential Information Iran Restrictive Covenants Stolen Goods Theft Trade Secrets

What Compliance Program?

At a recent luncheon, a representative of the U.S. Attorney’s Office in Los Angeles made some remarks that are helpful to all companies, regardless of size or industry. The context for the comments by this Assistant U.S....more

1/16/2014 - Compliance DOJ Financial Crimes Fraud

Do Your Employees Have the Proper Legal Training When It Comes to Government Investigations or Inquiries?

There is a general understanding that the Fifth Amendment to the U.S. Constitution gives a person the right not to incriminate him- or herself, and that understanding comes, in large measure, from movies and television...more

7/1/2013 - Fifth Amendment Government Investigations Miranda Warnings Self-Incrimination

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