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
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
May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian...more
Importer Pays $3.25M Settlement in FCA Case A California importer paid $3.25 million (Law360 subscription required to view) to settle a whistleblower suit brought by a former employee of its overseas supplier under the False...more
The U.S. Department of Commerce (Commerce) is increasing each civil monetary penalty within Commerce's jurisdiction for 2022 by 6.2 percent. The increases become effective on Jan. 15, 2022. Note that the 2022 adjustments will...more
On August 27, 2018, the U.S. Department of State implemented the first tranche of new sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act (the CBW Act). The enactment of these...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 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 July 8, 2013, the U.S. Departments of State and Commerce published final rules (78 Fed. Reg. 40892 and 40922), effective in 180 days (January 6, 2014), transferring export control jurisdiction over certain items previously...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