As many of you are aware, with some minor exceptions, the United States bifurcates export controls responsibility between the Department of State, which administers the International Traffic in Arms Regulations (the “ITAR”),...more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....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
I recently moderated a panel of legal experts on complying with multijurisdictional export and trade controls who provided an overview of the domestic and international regulatory environment to an audience of corporate...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
ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
On September 20, 2016, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department amended the Export Administration Regulations (EAR) and the list of goods, software and technology that are controlled under the...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
You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more
The United States officially removed Cuba from its list of State Sponsors of Terrorism today, according to an announcement by the U.S. State Department via Twitter. The change takes effect immediately, according to the...more
On April 14, President Obama notified Congress of his intent to rescind Cuba’s designation as a State Sponsor of Terrorism (SSOT), issued in March 1982, saying the Cuban government “has not provided any support for...more
The U.S. Department of Commerce, Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to restrict exports to Venezuela of certain items intended for “a military end use or end user.” ...more
On March 7 and 8, 2013, President Obama took two important steps to further U.S. export control reform. First, the President notified Congress of the proposed transfer of certain items relating to aircraft and gas turbine...more