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.
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9/6/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
Foreign Investment ,
International Trade ,
Investors ,
NPRM ,
Russia ,
Technology Sector ,
Uyghur Forced Labor Prevention Act (UFLPA)
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
5/9/2024
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
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
On April 5, the Department of Homeland Security (DHS) announced a plan to crack down on illicit trade in the textile industry. The announcement comes as DHS has been urged, especially by the textile industry, to more...more
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
On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had...more
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
3/15/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Employees ,
Entity List ,
Exports ,
Foreign Persons ,
Fraud ,
Iran ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Technology ,
U.S. Treasury ,
UK ,
Ukraine
January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more
2/8/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
United Arab Emirates (UAE)
December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more
1/10/2024
/ Commodities ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Financial Institutions (FFI) ,
International Trade ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury
On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation...more
12/21/2023
/ CFTC ,
Commodities ,
Commodities Traders ,
Corporate Governance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Regulatory Requirements ,
Settlement
In September 2022, Deputy Attorney General Lisa Monaco outlined the Department of Justice (DOJ) approach to enforcing corporate misconduct and directed agencies to review existing voluntary self-disclosure policies or, if...more
You are reading the November 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...more
12/8/2023
/ Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Sanction Violations ,
U.S. Treasury
Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain...more
October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more
11/9/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
General Licenses ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Requirements ,
Russia ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury ,
Venezuela
September saw a number of enforcement actions involving Iran. First, the Office of Foreign Assets Control (OFAC) announced separate settlements with 3M and Emigrant Bank for violations of the Iranian Transactions and...more
10/11/2023
/ Bureau of Industry and Security (BIS) ,
Department of Homeland Security (DHS) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Uyghur Forced Labor Prevention Act (UFLPA)
The U.S. government continues to aggressively monitor and impose restrictions on transactions deemed to threaten U.S. national security.
On a day-to-day basis, restrictions arise most commonly in the context of export...more
August saw two noteworthy Russia-related enforcement actions. First, a dual Russian-German national was arrested and charged with violating the Export Control Reform Act (ECRA) when he allegedly procured microelectronics for...more
9/11/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Convictions ,
Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Discrimination ,
Elon Musk ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
ITAR ,
Money Laundering ,
Russia ,
SpaceX ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Whistleblowers
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
8/17/2023
/ Antiboycott Requirements ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Foreign Entities ,
Foreign Nationals ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more
8/1/2023
/ CFIUS ,
Compliance ,
Department of Justice (DOJ) ,
Disclosure ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
You are reading the June 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.
- June saw...more
7/12/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Ghana ,
International Litigation ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Uyghur Forced Labor Prevention Act (UFLPA)
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
6/23/2023
/ Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Enforcement ,
Entity List ,
EU ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Secrets ,
U.S. Commerce Department
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
5/25/2023
/ China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
International Trade ,
Iran ,
North Korea ,
Russia
You are reading the March 2023 edition 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.
March saw...more
4/21/2023
/ Belarus ,
Criminal Convictions ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Fraudulent Procurement ,
Illegal Activity ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Settlement ,
U.S. Treasury
On March 22, the Department of Defense (DOD) issued a proposed rule that would amend the Defense Federal Acquisition Regulations (DFARS) to require certain contractors to provide the Defense Contract Management Agency (DCMA)...more
Russia -
Russian National Charged with Supplying U.S. Technology to the Russian and North Korean Governments (DOJ Action)
Those involved. Ilya Balakaev, Russian national.
Charges and penalties. Conspiracy to...more
3/16/2023
/ 3D Printing ,
Antitrust Violations ,
Austria ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Drones ,
E-Commerce ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Claims Act (FCA) ,
FBI ,
Iran ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Smuggling ,
Switzerland ,
U.S. Treasury ,
Ukraine