On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more
The discovery of actual or potential International Traffic in Arms Regulations (“ITAR”) violations presents the question of whether to disclose the conduct to the Department of State Directorate of Defense Trade Controls...more
WHAT: In a prior alert, we discussed a report from the Aerospace Industries Association (AIA), National Defense Industrial Association (NDIA), and Professional Services Council (PSC) presented to a U.S. Department of Defense...more
Compliance Program Guidelines - On December 5, 2022, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines (“the Guidelines”) intended to provide an overview...more
On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to...more
Joe Compliance has an export control issue involving definition of some of the terms being used. Joe goes to the website of the Directorate of Defense Trade Controls (pmddtc.state.gov) and clicks on “Review the ITAR.” He...more
Regulatory compliance is critical for any business involved in the export of defense related commodities. Violations under the International Traffic in Arms Regulation (ITAR) or the Export Administration Regulations (EAR) can...more
On September 7, 2021, three former U.S. Intelligence Community and military personnel (Defendants) entered into a Deferred Prosecution Agreement (DPA) with the U.S. Attorney’s Office for the District of Columbia and the U.S....more
1. Electronics Company Hit With $6.6 Million Penalty for Unauthorized Software Exports- Keysight Technologies Inc., a California electronics company, has settled with the Department of State, agreeing to pay a $6.6...more
This week, the Court knocks down a party’s argument that it was “de facto debarred” from exporting activities under the Arms Export Control Act, and explains what exactly triggers the statute of limitations in Wiretap Act...more
The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations. Last year, Quad Graphics earned a declination for FCPA and OFAC violations. In 2013, Weatherford settled...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
Etymology, particularly the Greek or Latin roots of words, aids our understanding in much the same way as root cause analysis does. The Greek word for disclosure is αποκάλυψη, transliterated to apokálypsi, or “apocalypse.”...more
Companies opting to file voluntary disclosures of potential export violations with the State Department’s Directorate of Defense Trade Controls (DDTC) will soon be required to utilize a new process for submitting their...more
The Directorate of Defense Trade Controls (“DDTC”) has issued a proposed regulation under the International Traffic In Arms Regulations (“ITAR”) that will have a significant impact on government contracts firms. Under the...more