FCPA Compliance Report – Episode 732 – Understanding Anti-Boycott Compliance with Alexander Cotoia
ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more
On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more
Our International Trade & Regulatory Group highlights changes to the voluntary self-disclosure process and penalty guidelines under the Export Administration Regulations by the Bureau of Industry and Security....more
On September 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule that requires reporting entities to make significant changes to Voluntary Self-Disclosures (“VSD”); the BIS...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) just issued a significant rule change that reshapes the landscape of export control enforcement. Published on September 16, 2024, the rule amends the...more
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
On May 17, 2024, Nevada-based DXC Technology Company (“DXC”)—a global IT services provider—officially filed its required annual 10-K Form with the U.S. Securities and Exchange Commission (“SEC”) indicating that...more
On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more
In a move that highlights the U.S. government’s ongoing fight against evasion of sanctions and export control laws, the Departments of the Treasury, Commerce, and Justice yesterday published yet another Tri-Seal Compliance...more
Last June (2023), in response to a ruling request from Your Special Delivery Services Specialty Logistics (YSDS), Customs and Border Protection (CBP) issued HQ H324098, clarifying what it means to be an “owner or purchaser”...more
On January 16, 2024, the Bureau of Industry and Security (BIS) under Assistant Secretary for Export Enforcement, Matthew Axelrod, disclosed significant enhancements to the process for Voluntary Self-Disclosures (VSDs) related...more
On January 16, 2024, the U.S Department of Commerce’s Bureau of Industry and Security (“BIS”) released a series of enhancements to its existing voluntary self disclosure (“VSD”) program, pursuant to which organizations...more
As many of you are aware, with some minor exceptions, the United States bifurcates export controls responsibility between the Department of State, which administers the International Traffic in Arms Regulations (the “ITAR”),...more
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
El 26/07/2023, el Departamento de Justicia de los EE. UU. (DOJ), la Oficina de Industria y Seguridad del Departamento de Comercio de los EE. UU. (BIS) y la Oficina de Control de Activos Extranjeros (OFAC) del Departamento del...more
On 07/26/2023, the U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), issued a...more
On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a...more
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
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities, a reminder that the False Claims Act increasingly is being used as a weapon...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) continues to send a strong and clear message to the exporting community – it wants businesses and universities to voluntarily disclose any significant...more
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
On April 18, 2023, the U.S. Department of Commerce (“Commerce”)’s Assistant Secretary for Export Enforcement issued a Memorandum titled “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning...more
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
In concert with the Department of Justice’s (DOJ) focus on voluntary self-disclosure of corporate misconduct, as well as DOJ’s commitment to addressing sanctions evasion, export control violations and similar economic crimes,...more