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Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China

On February 11, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Applied Materials, Inc. (AMAT) and Applied Materials Korea, Ltd. (AMK) resolving allegations that the...more

OFAC Enforcement Update: $1.72M Settlement Highlights Screening Gaps in Education, Similar Sectors

On February 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $1.72 million settlement with IMG Academy, LLC (IMG) arising from apparent violations of OFAC’s counternarcotics...more

Export Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty

On January 7, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Order resolving allegations that Exyte Management GmbH (Exyte), a Germany-based company, committed 13 violations of the Export...more

Update on Venezuela: Significant Trade Restrictions and Risks Continue

We hope everyone had a great holiday. 2026 is now officially off and running, and particularly in light of recent events, we want to briefly summarize current trade restrictions related to Venezuela....more

UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China

On October 30, U.S. Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will delay the implementation of the recently announced BIS Affiliates Rule for one...more

BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities

On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to...more

Huge Export Penalty for U.S. Technology Company

On July 28, various arms of the U.S. government announced concurrent export enforcement resolutions involving Cadence Design Systems, Inc. (Cadence), a California-based software and technology firm. Cadence will pay over $140...more

U.S. Government Ends Sanctions on Syria

On June 30, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has...more

CFIUS and President Trump Force Unwinding of 2020 Acquisition of Jupiter Systems, LLC

On July 11, the Trump administration issued an order blocking and requiring the unwinding of a 2020 acquisition by which Jupiter Systems, LLC (Jupiter), a U.S.-based audiovisual equipment supplier, was acquired by Suirui...more

U.S. Government Eases Some Restrictions on Syria

On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S....more

America First Investment Policy Sets Sights on China

On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and...more

Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations

On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil...more

CTA Beneficial Ownership Information Reporting Requirements Resume March 21, 2025; Preliminary Injunctions Lifted

On February 18, the U.S. District Court for the Eastern District of Texas lifted the preliminary injunction against enforcement of the Corporate Transparency Act (CTA) and the beneficial ownership reporting rule promulgated...more

Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty

In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the...more

International Trade Enforcement Roundup – December 2024

You are reading the December 2024 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. - An...more

International Trade Enforcement Roundup – November 2024

You are reading the November 2024 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. -...more

International Trade Enforcement Roundup – October 2024

You are reading the October 2024 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. -...more

International Trade Enforcement Roundup – September 2024

What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more

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

International Trade Enforcement Roundup – April 2024

You are reading the April 2024 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. April saw...more

CFIUS Update: Larger Penalties, Sharper Monitoring

On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more

International Trade Enforcement Roundup – March 2024 Update

You are reading the March 2024 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. Overview...more

International Trade Enforcement Roundup – February 2024 Update

February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more

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