Episode 315 - Boeing Pays $51 Million for ITAR Violations
Season 2 Episode 4 - Russia Enforcement and the involvement of DOJ's Task Force KleptoCapture
The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...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 Bureau of Industry and Security (BIS) issued new guidance to prevent the diversion of controlled items to Russia. This guidance recommends the use of the Trade Integrity Project (TIP) database, which tracks suppliers with...more
To curtail U.S. persons from supporting the efforts of adversarial regimes, such as China and Russia, in advancing their military and intelligence capabilities, the U.S. is proposing a significant expansion of export control...more
Canada has long enjoyed International Traffic in Arms Regulations (ITAR) license exemptions and minimal controls for items subject to the Export Administration Regulations (EAR). What about some of our other friends, such as...more
Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
The U.S. agencies most well-known for their enforcement of U.S. trade and national security laws are the Bureau of Industry and Security (“BIS”), the Directorate of Defense Trade Controls (“DDTC”), the Office of Foreign...more
On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more
Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more
TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more
On October 30, 2023, the Biden-Harris Administration unveiled a sweeping Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (AI). The Executive Order represents the most...more
On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more
WHAT: Over the past year, there have been indications that changes would be coming to the U.S. Government’s defense trade industry. From the Foreign Military Sales (FMS) Tiger Team established by the U.S. Department of...more
WHAT: In a prior alert, we discussed a report from the Aerospace Industries Association (AIA), National Defense Industrial Association (NDIA), and Professional Services Council (PSC) presented to a U.S. Department of Defense...more
The U.S. Department of State (State Department) and U.S. Department of Commerce (Commerce Department), have recently previewed, proposed or finalized changes to relevant trade controls. These new regulatory updates include...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
Regulatory compliance is critical for any business involved in the export of defense related commodities. Violations under the International Traffic in Arms Regulation (ITAR) or the Export Administration Regulations (EAR) can...more
On June 29, 2022 through July 1, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held its 35th Annual Update Conference on Export Controls and Policy (Update) in Washington, D.C. This important...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
On December 9, 2021, the Departments of Commerce and State issued rules restricting a range of exports to Cambodia citing, “significant evidence of corruption, human rights abuses, and an exclusive agreement with the People’s...more
On September 7, 2021, three former U.S. Intelligence Community and military personnel (Defendants) entered into a Deferred Prosecution Agreement (DPA) with the U.S. Attorney’s Office for the District of Columbia and the U.S....more
As part of the United States’ response to Russia’s use of chemical weapons against Russian opposition figure Aleksey Navalny, the U.S. State Department applied a policy of denial to licenses and other approvals for exports to...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 June 30, 2020 at 11:00 PM Hong Kong time, the Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong Special Administrative Region (HK National Security Law) took effect....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