Today, President Obama announced a landmark agreement with Iran designed to prevent Iran from obtaining a nuclear weapon in exchange for lifting sanctions that have retarded the country’s development for the decades since the...more
On June 16, 2015, IAP Worldwide Services Inc., a private defense and government contracting company, agreed to pay $7.1 million to settle criminal charges of the U.S. Foreign Corrupt Practices Act (FCPA) related to bribing...more
On March 25, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that PayPal Inc. (“PayPal”) agreed to pay $7.7 million to settle 486 violations of U.S. economic sanctions. According to OFAC,...more
4/2/2015
New regulations on Cuba enter into force today, only 29 days after President Obama promised them. The liberalized provisions focus on support for private sector actors in Cuba. As we described here, the President announced on...more
The Department of Justice’s Kleptocracy Initiative is kicking off 2015 strong. On January 13, 2015, the DOJ filed a civil complaint seeking the forfeiture of nine properties in New Orleans, worth close to $1.53 million. The...more
Today President Barack Obama made a stunning speech announcing steps the United States will take to reduce U.S. sanctions against Cuba. The announcement followed the release of two U.S. citizens held by the Cuban government....more
In a recent Opinion Procedure Release (OPR), Number 14-02, the U.S. Department of Justice expressly limited successor liability for a US company purchasing a non-US company that had paid bribes in the past. In so doing, DOJ...more
On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently...more
SBA Proposes to Increase Small Business Size Standards (79 Fed. Reg. 54145; 79 Fed. Reg. 53646) -
The U.S. Small Business Administration (“SBA”) proposes to increase small business size standards for: (1) 209...more
On August 14, 2014, Joel Esquenazi and Carlos Rodriguez filed a Petition for a writ of certiorari in the U.S. Supreme Court seeking clarification of a key term in the Foreign Corrupt Practices Act. Among other arguments,...more
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
7/16/2014
/ Aerospace ,
Bureau of Industry and Security (BIS) ,
Burma ,
Enforcement ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Fokker ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanctions ,
Settlement ,
Sudan ,
Trade Policy
As we continue to find new ways to look at the implications of the Ukraine-related sanctions introduced by the United States over the past few months, we have shifted our perspective to the extra-terrestrial to focus on the...more
In February 2014, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a report (“Report”) detailing the impact of export controls on the U.S. space industry. Titled the “U.S. Space Industry...more
In Episode I and Episode II of this series, we discussed some key points of U.S. Export Control Reform and took you through a step-by-step reclassification analysis of parts and components transitioning from the USML to the...more