Episode 315 - Boeing Pays $51 Million for ITAR Violations
Season 2 Episode 4 - Russia Enforcement and the involvement of DOJ's Task Force KleptoCapture
On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational...more
In May, the US State Department’s Directorate of Defense Trade Controls (DDTC) published its long-awaited rule amending the International Traffic in Arms Regulations (ITAR) to implement the AUKUS Trilateral Security...more
The U.S. State Department has proposed amendments to the International Traffic in Arms Regulations (ITAR) to increase the fees required for Directorate of Defense Trade Controls (DDTC) registration. The ITAR requires persons...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes the key export restrictions...more
On January 5, 2023, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published updated guidance concerning authorizations issued to U.S. Persons Abroad (“USPABs”) as defined in 22 C.F.R. Section...more
On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to...more
The International Traffic in Arms Regulations, administered by the U.S. Department of State’s Directorate of Defense Trade Controls, and the Export Administration Regulations, administered by the U.S. Department of Commerce’s...more
The Directorate of Defense Trade Controls (DDTC) has embarked on a series of revisions to the International Traffic In Arms Regulations (ITAR) to clarify and better organize the ITAR. The first round of revisions is to...more
Even a layperson understands that the U.S. government regulates the export of military hardware. Defense contractors involved in such international transactions adhere to the International Traffic in Arms Regulation, or ITAR...more
A recent export enforcement case describes a common compliance challenge faced by many U.S. companies. In this case, a California company manufactured electronic test and measurement equipment for both commercial and...more
Part 129 of the International Traffic in Arms Regulations (“ITAR”) requires certain persons engaged in “brokering activities” to register with, and pay a fee to, the U.S. Department of State Directorate of Defense Trade...more
The State Department’s Directorate of Defense Trade Controls (DDTC) took a number of significant actions to expand the list of destinations listed as “Proscribed Countries” in ITAR §126.1. This is an important compliance...more
For a whole decade, ACI’s U.S. Export & Reexport Compliance for Canadian Operations conference continues to stand apart as the only practical, comprehensive event of its kind for the export compliance community in Canada. ...more
- On May 1, 2020, the State Department’s Directorate of Defense Trade Controls (DDTC) temporarily revised certain International Traffic in Arms Regulations (ITAR) requirements due to the ongoing COVID-19 pandemic. On May 6,...more
- On March 31, 2020, DDTC published five new FAQs on activities that non-U.S. persons may engage in following the expiration of a Technical Assistance Agreement (TAA) or Manufacturing Licensing Agreement (MLA). - The FAQs...more
On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations. Last year, Quad Graphics earned a declination for FCPA and OFAC violations. In 2013, Weatherford settled...more
In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more
On 6 January 2020, the State Department's Directorate of Defense Trade Controls (DDTC) issued new frequently asked questions (FAQs) regarding the registration and licensing requirements under the International Traffic in Arms...more
On 6 January, 2020 DDTC announced guidance regarding U.S. persons providing defense services while abroad. ...more
The State Department’s Directorate of Defense Trade Controls (“DDTC”) published an interim final rule on December 26, 2019, bringing the International Traffic in Arms Regulations’ (“ITAR”) treatment of encrypted electronic...more
• On January 6, 2020, DDTC published a new FAQ on Defense Services Performed by U.S. Persons Abroad, confirming that the ITAR regulate defense services performed by a U.S. person employed by a non-U.S. company outside of the...more