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Enforcement Bureau of Industry and Security (BIS)

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Dechert LLP

BIS Enhances Its Voluntary Self-Disclosure Process and Related Enforcement Guidance

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (the “Rule”) regarding changes to the provisions of the Export Administration Regulations (the “EAR”) governing voluntary...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – Summer 2024

You are reading the Summer 2024 Update of the Bass, Berry & Sims Enforcement Roundup. After a short hiatus, we are back to reporting on notable enforcement actions and policy changes and providing a bit of our insight. -...more

Dechert LLP

Read All About It: CFIUS Publishes Enforcement Information

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After over a year of preview, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) has finally published information on its most recent enforcement actions. The actions were announced on...more

Fenwick & West LLP

BIS Report Highlights Increased U.S. Export Controls Enforcement and Risks to Industry

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The Bureau of Industry and Security (BIS) released its latest Don’t Let This Happen to You! report, summarizing recent U.S. export control civil and criminal enforcement actions....more

Snell & Wilmer

United States Government Doubles Statute of Limitations for Sanctions Violations

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Shrouded within the supplemental emergency appropriations bill for Israel, Ukraine, and Taiwan, the 21st Century Peace through Strength Act passed by Congress and signed into law significantly increases the statute of...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

Adams and Reese LLP

International Compliance Digest – May 2024

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May saw the long-awaited release of the USTR’s Section 301 review. USTR confirmed that the Trump-era tariffs will remain in place, and raised those tariffs by another $18 billion on manufacturing, critical minerals, solar...more

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

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President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more

Ankura

U.S. Department of Commerce Issues Proposed Rule Impacting AI and U.S. IaaS Providers to Counter Foreign Malicious Actors

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On January 29, 2024, the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued a new proposed regulatory rule (the “Proposed Rule”), which will impose significant diligence, monitoring, and reporting...more

Skadden, Arps, Slate, Meagher & Flom LLP

Know Your Cloud Customer: Commerce Department Proposes To Regulate Foreign Access to US IaaS Products

On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - February 2024 - BIS Unveils Enhanced Voluntary Self Disclosure Protocols

On January 16, 2024, the Bureau of Industry and Security (BIS) under Assistant Secretary for Export Enforcement, Matthew Axelrod, disclosed significant enhancements to the process for Voluntary Self-Disclosures (VSDs) related...more

Akin Gump Strauss Hauer & Feld LLP

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Seward & Kissel LLP

“Quint-Seal” Compliance Note Highlights Intensifying U.S. Government Enforcement of Sanctions and Export Control Laws in the...

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On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Sheppard Mullin Richter & Hampton LLP

Antiboycott Update for Government Contractors and More

The U.S. antiboycott laws and regulations have been around since the era of disco. In stark contrast to fast-moving sanctions and export controls, we rarely see updates to the antiboycott regulations or enforcement...more

Benesch

Anti-Boycott Restrictions Remain Relevant Today

Benesch on

Anti-boycott rules are one of the lesser raised issues across clients involved in international trade or in servicing those movements, but the issue does arise. The rules originated in the Export Administration Act of 1979...more

Pillsbury Winthrop Shaw Pittman LLP

Voluntary Self-Disclosure: Is the Value Self-Evident?

How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement? The DOJ, BIS and OFAC released a joint compliance note...more

Seward & Kissel LLP

Tri-Seal Compliance Note Encourages Voluntary Self-Disclosure of Potential Violations of Sanctions and Export Control Laws to DOJ,...

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The ascending importance of rigorous and compliance with U.S. national security laws, including sanctions and export controls, was underscored on July 26, 2023 with the release of a Department of Commerce, Department of the...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – May 2023 Update

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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

Davis Wright Tremaine LLP

A New Era for U.S. Export Controls and Human Rights?

On March 30, 2023, the United States and over 20 additional Subscribing States released a "Code of Conduct for Enhancing Export Controls of Goods and Technology That Could be Misused and Lead to Serious Violations or Abuses...more

Foley Hoag LLP

Launch of the Disruptive Technology Strike Force – Top Takeaways

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On April 28, 2023, U.S. Attorney for the District of Massachusetts Rachel Rollins, joined by national and local federal enforcement officials from the Disruptive Technology Strike Force (DTSF), described the DTSF mission and...more

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