News & Analysis as of

Enforcement Actions Export Administration Regulations (EAR)

The Volkov Law Group

RTX Corporation Reaches Record $200 Million Settlement with DDTC for Serial Violations of the AECA and ITAR

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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

The Volkov Law Group

BIS Reaches Settlement of $5.8 Million Enforcement Action with TE Connectivity Corporation over Export of EAR99 Commodities

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On August 15, 2024, the U.S. Department of Commerce’s Office of Export Enforcement (“OEE”) announced the settlement of the latest administrative enforcement action involving TE Connectivity Corporation—a Pennsylvania-based...more

Adams and Reese LLP

International Compliance Digest – July 2024

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July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

The Volkov Law Group

BIS Announces Settlement Agreement with Indiana University Over Export Control Violations

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On June 24, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the settlement of an administrative enforcement action involving Indiana University of Bloomington (“Indiana University”)...more

Adams and Reese LLP

International Compliance Digest - June 2024

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Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more

The Volkov Law Group

BIS Issues Denial Order for Domestic Freight Forwarder Alleging Multiple Violations of Settlement Agreement Terms

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On June 14, 2024, U.S. Department of Commerce Assistant Secretary for Export Enforcement, Matthew Axelrod, officially issued an order activating the suspended portion of a civil penalty that was imposed on U.S-based freight...more

The Volkov Law Group

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

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We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have...more

The Volkov Law Group

BIS Announces Settlement of Antiboycott Violations with Airbus Space and Defense Subsidiary

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On June 3, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the resolution of an administrative enforcement action brought against Airbus DS Government Solutions (“Airbus DSGS”)—a...more

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

The Volkov Law Group

BIS Imposes $153,175 Penalty Against Wabtec Corporation to Resolve Multiple Violations of Antiboycott Regulations

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Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more

Ankura

DOD Issues Memo on FedRAMP Requirements for Defense Contractors

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On December 21, 2023, the Department of Defense (DoD) issued a memorandum (Memo) providing guidance and clarification on the security and cyber incident management requirements applicable for the use of external Cloud Service...more

Torres Trade Law, PLLC

Trade Violations Under the False Claims Act

On February 7, the U.S. Department of Justice (DOJ) announced that settlements and judgements under the False Claims Act (FCA) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the second-highest...more

The Volkov Law Group

A Recap of Significant Export Control Enforcement Efforts from 2023

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As global political tensions continued to escalate on multiple fronts, the 2023 calendar year saw a noticeable increase in the number of enforcement actions initiated by the U.S. government against entities and individuals...more

The Volkov Law Group

BIS Signals New Enforcement Initiative for Antiboycott Compliance — Pratt and Whitney Settles Antiboycott Violations

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On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and relatively rare enforcement action...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – August 2023 Update

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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

Foley Hoag LLP

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Regarding Self-Disclosure of Potential Sanctions Violations

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On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more

American Conference Institute (ACI)

[Webinar] Export Administration Regulations - September 12th - October 5th, 1:00 pm - 4:30 pm EDT

ACI’s highly anticipated Proficiency Series provides true immersion in the EAR with the objective of becoming proficient in four weeks. Join virtually from September 12 – October 5, 2023! Advance your career and...more

Pillsbury Winthrop Shaw Pittman LLP

Where Employment and Trade Compliance Intersect—Protecting Your Company in a World of Dueling Enforcement Risks for Export...

In a new enforcement action against GM, the Department of Justice (DOJ) Civil Rights Division emphasizes that employers subject to export control obligations must still comply with federal laws against discrimination on the...more

Hogan Lovells

U.S. Commerce Department: failure to report export control violation is aggravating factor

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) clarified its policy regarding voluntary self-disclosures and enforcement actions on April 18, 2023. Historically, a failure to voluntarily...more

K&L Gates LLP

US Government to Penalize Failures to Disclose Possible Export Control Violations and Incentivize Reporting of Others' Violations

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A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing policies that favor such disclosure by...more

Venable LLP

New Carrot, New Stick: Commerce Encourages Voluntary Self-Disclosures and Disclosures on Others for Potential Export Control...

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On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more

Eversheds Sutherland (US) LLP

BIS imposes historic settlement for alleged Huawei-related violations of the Entity List Foreign Direct Product Rule

On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more

The Volkov Law Group

Bureau of Industry and Security Extracts $300 Million Fine Against Seagate Technology for Violation of Huawei Prohibition

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Matt Axelrod, the Assistant Secretary for Export Enforcement, at the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, must be grinning with satisfaction that BIS delivered, in a big way, after he...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2023

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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

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