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
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
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 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
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
Russia -
Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ)
Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
2/8/2023
/ Banking Sector ,
Bureau of Industry and Security (BIS) ,
California ,
China ,
Conspiracies ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Labor (DOL) ,
Enforcement Actions ,
Espionage ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FBI ,
FCPA Corporate Enforcement Policy (CEP) ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Iran Sanctions ,
Money Laundering ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Self-Disclosure Requirements ,
Venezuela
Russia -
Active Russian Agent Indicted for Scheme to Violate Sanctions in the United States (DOJ Action)
Those involved. Andrii Derkach, a Ukrainian national and – according to the DOJ – an “Active Russian Agent.”...more
1/13/2023
/ China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Securities and Exchange Commission (SEC) ,
Settlement
You are reading Bass, Berry, & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.
...more
12/9/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Illegal Imports ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Secrets
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
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
This UPDATED post summarizes the situation as of late evening on Monday, February 28, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
3/1/2022
/ Asset Freeze ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Friday, February 25, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
2/28/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Licensing Rules ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Commerce Department ,
Ukraine ,
Vladimir Putin
This UPDATED post summarizes the situation as of late evening on Thursday, February 24, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This supplements our post of late evening on...more
On February 22, President Biden issued Executive Order14,024 (the EO), which authorizes the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) to designate Russian and other entities and individuals involved in...more
2/24/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
Even well-established companies can struggle to understand and comply with the U.S. laws that govern international trade. The challenges are greater still for new companies with limited experience doing cross-border...more
11/23/2021
/ Business Partners ,
Compliance ,
Cross-Border ,
Early Stage Companies ,
Emerging Growth Companies ,
Export Controls ,
Exports ,
Foreign Business Partners ,
International Trade ,
Startups ,
Technology ,
Third-Party
On October 12, the U.S. Commerce Department, Bureau of Industry and Security (BIS) announced that it imposed a civil penalty fine against VTA Telecom Corporation (VTA) for the unauthorized export of controlled commodities to...more
On September 28, the U.S. Commerce Department, Bureau of Industry and Security (BIS) announced that it has imposed a civil penalty fine and denial of export privileges against Vorago Technologies (Vorago) for the unauthorized...more
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
8/20/2021
/ China ,
Commodities ,
Consent Agreements ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
ITAR ,
Penalties ,
Russia ,
Software ,
Technology
On February 1, the U.S. Commerce Department, Bureau of Industry & Security (BIS), announced a settlement (available here) with Princeton University in connection with 37 alleged violations of the Export Administration...more
Despite the sobering news reports on the global spread of COVID-19, companies are continuing to try to conduct operations as (relatively) normally as possible. International business is particularly affected given the...more
• Company committed multiple apparent violations of U.S. sanctions on North Korea
• Penalty imposed in part because of company’s “non-existent” sanctions compliance program
• Settlement underscores need to address supply...more
2/8/2019
/ China ,
Corporate Counsel ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Settlement Agreements ,
Supply Chain
• Russian corporations de-listed through significant specific steps agreed to with OFAC
• Exporter settles for $7.7 million and agrees to comprehensive compliance measures
• OFAC outlines sanctions compliance best...more
1/4/2019
/ Audits ,
Best Practices ,
Certifications ,
Delisting ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Fifty Percent Rule ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Russia ,
SDN List ,
Settlement Agreements
• Economic sanctions and export restrictions extended
• Russian investment in United States likely subject to heightened scrutiny
• Diligence on Russia transactions and business partners is essential to ensure...more
9/27/2018
/ CAATSA ,
CBW Act ,
CFIUS ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
FIRRMA ,
Foreign Investment ,
Foreign Policy ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Trump Administration ,
U.S. Treasury
• 7-year denial order imposed against Chinese telecommunications equipment maker
• Denial order strictly limits business with company
• Action comes as U.S. imposes other trade restrictions on China
On April 16, U.S....more
4/23/2018
/ CFIUS ,
China ,
Economic Sanctions ,
Export Controls ,
Exports ,
Mergers ,
National Security ,
Sanction Violations ,
Semiconductors ,
Telecommunications ,
Trump Administration