Many Americans value domestically made goods. A “Made in USA” label can hold special meaning for these consumers, as it serves as a symbol of patriotism, a sign of quality craftsmanship, and a show of solidarity with local...more
9/12/2024
/ Buy American Act ,
Country of Origin ,
Customs and Border Protection ,
Due Diligence ,
Federal Trade Commission (FTC) ,
FTC Act ,
Labeling ,
Made in the USA ,
Marketing ,
Multinationals ,
Penalties ,
Regulatory Standards
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
CFIUS is an interagency committee that evaluates the national security implications of foreign investments on the U.S. economy and infrastructure. CFIUS possesses statutory authority to “make an investigation to determine the...more
The risks for international investments have sharply expanded in recent years. Identifying, managing, and mitigating investment risk, in the current regulatory environment, can be just as essential as managing risk in any...more
8/2/2024
/ Acquisitions ,
Anti-Corruption ,
Anti-Dumping Duty ,
Anti-Money Laundering ,
Antitrust Provisions ,
CFIUS ,
Compliance ,
Countervailing Duties ,
Due Diligence ,
ECCNs ,
Employee Training ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Imports ,
Mergers ,
Military Service Members ,
Multinationals ,
Supply Chain ,
Tariffs ,
Uyghur Forced Labor Prevention Act (UFLPA)
...As covered in previous articles in our biweekly series, the U.S. government maintains prohibitions on participating in the Arab League boycott of Israel. Especially for companies that frequently deal with the Middle East,...more
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
We have received a number of inquiries regarding the implications of the new solar panels antidumping (AD) and countervailing duty (CVD) investigations. With the ITC just issuing its affirmative preliminary determination, we...more
7/5/2024
/ Anti-Discrimination Policies ,
Countervailing Duties ,
Importers ,
Imports ,
International Trade ,
International Trade Commission (ITC) ,
Manufacturers ,
Multinationals ,
Solar Panels ,
Supply Chain ,
Tariffs
As an accompaniment to our biweekly series on What Every Multinational Should Know About various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that every...more
During the mid-1970’s, the U.S. adopted two laws that seek to counteract the participation of U.S. citizens in other nations’ economic boycotts or embargoes. These antiboycott laws are the 1977 amendments to the Export...more
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
3/21/2024
/ Anti-Corruption ,
Buyers ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Multinationals ,
Regulatory Agenda ,
Risk Management ,
Sellers ,
Supply Chain ,
U.S. Commerce Department
We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
3/7/2024
/ Anti-Corruption ,
Antiboycott Requirements ,
Billing ,
Compliance ,
Economic Sanctions ,
Enforcement ,
Ethical Standards ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Multinationals ,
Recordkeeping Requirements ,
Reputation Management ,
Risk Assessment ,
Risk Mitigation
Share on Twitter Print Share by Email Share Back to top In Part I and Part II of “What Every Multinational Company Needs to Know About … The Uyghur Forced Labor Prevention Act” (UFLPA), we summarized the UFLPA requirements...more
2/23/2024
/ Compliance ,
Corporate Counsel ,
Customs and Border Protection ,
Forced Labor ,
Human Trafficking ,
Internal Controls ,
International Trade ,
Multinationals ,
New Guidance ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
In our previous biweekly update, What Every Multinational Needs to Know About … The Uyghur Forced Labor Prevention Act, Part I, we summarized the UFLPA requirements and the basic expectations that U.S. Customs and Border...more
2/1/2024
/ Compliance ,
Corporate Counsel ,
Customs and Border Protection ,
Due Diligence ,
Forced Labor ,
Human Trafficking ,
Imports ,
International Trade ,
Multinationals ,
Risk Management ,
Supply Chain ,
Transparency ,
Uyghur Forced Labor Prevention Act (UFLPA)
We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more
1/4/2024
/ Anti-Corruption ,
Anti-Discrimination Policies ,
Anti-Harassment Policies ,
Anti-Retaliation Provisions ,
Antitrust Provisions ,
Books & Records ,
Code of Conduct ,
Compliance ,
Conflicts of Interest ,
Copyright ,
Customs ,
Cybersecurity ,
Data Protection ,
Document Retention Policies ,
Economic Sanctions ,
Ethics ,
Export Controls ,
Family and Medical Leave Act (FMLA) ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Imports ,
Insider Trading ,
Internal Controls ,
Litigation Hold ,
Multinationals ,
Popular ,
Privacy Laws ,
Risk Mitigation ,
Social Media ,
Supply Chain ,
Trademarks ,
Uyghur Forced Labor Prevention Act (UFLPA)
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
6/13/2019
/ Chief Compliance Officers ,
Compliance ,
Due Diligence ,
Enforcement ,
Export Administration Regulations (EAR) ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Standards ,
Risk Management ,
Supply Chain
We are now two years into the current presidential administration and regulators have imposed three of the ten largest Foreign Corrupt Practices Act penalties in history and the largest export controls penalty of all time....more
2/26/2019
/ Anti-Corruption ,
Antitrust Provisions ,
Audits ,
Automotive Industry ,
Compliance ,
Department of Justice (DOJ) ,
Export Controls ,
Exports ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Multinationals ,
Risk Assessment ,
Risk Management ,
Supply Chain
An open question coming into 2017 was whether the aggressive enforcement posture that had characterized the Obama and Bush administrations would continue under the Trump administration. Any questions were answered with the...more
3/19/2018
/ Anti-Bribery ,
Anti-Corruption ,
Automotive Industry ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement Actions ,
Exports ,
Extraterritoriality Rules ,
Foreign Corrupt Practices Act (FCPA) ,
Joint Comprehensive Plan of Action (JCPOA) ,
Manufacturers ,
Multinationals ,
NAFTA ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Tariffs ,
Trade Policy ,
Trump Administration
Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more
2/11/2017
/ Affordable Care Act ,
Anti-Corruption ,
Anti-Money Laundering ,
Attorney General ,
Bribery ,
CFIUS ,
Civil Monetary Penalty ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Penalties ,
Criminal Prosecution ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Dual Use Goods ,
Economic Sanctions ,
Employee Training ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Extraterritoriality Rules ,
False Claims Act (FCA) ,
FBI ,
Financial Fraud ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Internal Audit Functions ,
Internal Controls ,
ITAR ,
Multinationals ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Political Appointments ,
Risk Management ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Terrorist Financing Regulations ,
Trump Administration ,
U.S. Commerce Department ,
Whistleblower Awards ,
White Collar Crimes ,
Yates Memorandum
Globalization and the need to efficiently deploy corporate resources have led many multinational companies to establish global supply networks. Although these efforts often lead to the efficient deployment of capital,...more
1/11/2017
/ Anti-Dumping Duty ,
China ,
Countervailing Duties ,
Cross-Border Transactions ,
Customs and Border Protection ,
Exports ,
False Claims Act (FCA) ,
Imports ,
International Trade Commission (ITC) ,
Manufacturers ,
Most-Favored Nations ,
Multinationals ,
NAFTA ,
Remedies ,
Section 301 ,
Section 337 ,
Tariffs ,
Trade Expansion Act of 1962 ,
Trump Administration ,
U.S. Commerce Department ,
Unfair Trade Practices Act ,
WTO
In last month’s newsletter, we discussed how developments in 2012 had considerably tightened sanctions against Iran, including through the first-ever application of sanctions to separately incorporated subsidiaries of U.S....more