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
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)
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
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
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
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
10/4/2022
/ Aircraft ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
General Licenses ,
Intelligence Services ,
Iran ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Technology Sector ,
U.S. Treasury ,
Ukraine
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
The U.S. Treasury Department, Office of Foreign Assets Control (OFAC), the main U.S. government body that administers U.S. economic sanctions and embargoes, continues to be busy. In September 2019 alone, OFAC has announced...more
9/27/2019
/ China ,
Economic Sanctions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Settlement Agreements ,
Sudan ,
Trade Relations ,
Trump Administration ,
Unfair or Deceptive Trade Practices ,
Venezuela
- Boeing announces deal to sell aircraft to Iran Aseman
- The deal was apparently authorized by the U.S. Treasury Department, but Congressional foes fight to block it
- If the deal goes through, further loosening of...more
Effective December 23, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of medical devices that can be exported to...more
Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more
11/29/2016
/ Civil Monetary Penalty ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Iran ,
Iran Sanctions ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement ,
UK
With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more
11/22/2016
/ Barack Obama ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
Federal Contractors ,
General Licenses ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Repeal ,
Russia ,
Trump Administration
Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more
11/2/2016
/ Certification Requirements ,
Economic Sanctions ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
System For Award Management (SAM)