News & Analysis as of

Enforcement Export Administration Regulations (EAR)

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...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

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

Benesch

Anti-Boycott Restrictions Remain Relevant Today

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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

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (June 21, 2023)

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Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities, a reminder that the False Claims Act increasingly is being used as a weapon...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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – April 2023 Update

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You are reading the April 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -We saw...more

Venable LLP

New Carrot, New Stick: Commerce Encourages Voluntary Self-Disclosures and Disclosures on Others for Potential Export Control...

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On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more

ArentFox Schiff

More Stick Than Carrot for “Significant” Export Violations from the Bureau of Industry & Security Office of Export Enforcement

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Voluntary No More - In taking steps to take the “voluntary” out of voluntary disclosure, Assistant Secretary of US Export Enforcement Matthew Axelrod issued another memorandum on April 18, 2023, following on his June 2022...more

Torres Trade Law, PLLC

BIS to Industry: Please Disclose “Big Deal” Violations and Whistle Blow on Others for Credit

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In a memorandum published by the Bureau of Industry and Security on April 18, 2023, the Office of Export Enforcement (OEE) announced that it wants to incentivize voluntary self-disclosures (VSDs) after a party uncovers...more

Ankura

BIS Issues Important Policy Changes on Trade Controls Violations Prevention and Enforcement

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Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations....more

Foley Hoag LLP

Department of Commerce’s Bureau of Industry and Security Eyes Enforcement and Voluntary Disclosure Review Policy Changes

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June 23, 2022 Key Takeaways: In two recent speeches, Matthew Axelrod, Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (“BIS”), has signaled policy changes related to...more

Bass, Berry & Sims PLC

Russia, Ukraine: Update as of June 6

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more

K2 Integrity

Sanctions Against Russia: The Week in Review. - April 2022

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The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

Husch Blackwell LLP

BIS Signals Aggressive Enforcement Approach to Russia-Related EAR Violations

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On March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of the Export...more

Foley Hoag LLP - White Collar Law &...

Review of Sanctions and Export Control Developments in 2021 and What to Expect in 2022

This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more

Williams Mullen

Export Agencies Continue Emphasis on Restricted Party Screening Under Export Control Laws

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The U.S. Government is continuing its frequent and highly visible use of denied party lists as an important tool in administering the export control laws. Each of the Bureau of Industry and Security (BIS), the Office of...more

ArentFox Schiff

Uyghur Forced Labor Prevention Act Becomes Law: Importers Must Prepare for Increased Enforcement and Detentions at the Border

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US importers should participate in the Task Force's comment and hearing process to flag due diligence challenges and formulate the strategy to enforce the import prohibitions. What to Know - Effective June 21, 2022, 180...more

Bass, Berry & Sims PLC

Export Enforcement Update: The Importance of Commodity Classification

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On August 3, 2021, the U.S. State Department Directorate of Defense Trade Controls (DDTC) issued an order laying out charges and imposing a monetary penalty of $6.6 million on Keysight Technologies, a U.S. technology and...more

Foley Hoag LLP - White Collar Law &...

Sanctions/Export Controls Trends in 2021

This is the second in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed SEC enforcement. Up next,...more

Foley & Lardner LLP

Managing the Aggressive Enforcement of International Regulations by the Trump Organization: Compliance Best Practices for...

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With the Trump administration having put in place the largest export controls penalty of all time, the second-largest economic sanctions/OFAC penalty, and five of the ten largest FCPA penalties, international regulatory risk...more

Sheppard Mullin Richter & Hampton LLP

Don’t try this at Home or Abroad: Export Controls and Sanctions Violations Lead to $21 Million in Penalties for Dutch Company...

We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more

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