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
On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of...more
During an investment forum in Riyadh, Saudi Arabia, on May 13, 2025, President Donald Trump announced his intent to lift sanctions on Syria, stating that sanctions relief will "give them a chance at greatness."...more
On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more
The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more
On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more
On December 2, 2024, the Bureau of Industry and Security (BIS) issued a final rule expanding and refining the scope of the Entity List (the “Entity List FR”), as well as an interim final rule building upon the China chip...more
I. US SANCTIONS - US Department of the Treasury Acts to Curtail Russia’s Use of the International Finance System: On November 21, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated...more
U.S. export controls on space-related items were last significantly revised in 2014. Since then, the industry has continued to evolve towards a wider range of public-private partnerships and purely commercial activities,...more
On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its first-ever guidance to financial institutions (“FIs”) on best practices to comply with the Export Administration...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
On September 30, 2024, Quantum Corporation—a U.S.-based technology company— reached a settlement with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) to resolve 45 separate violations of the...more
On August 14, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) issued guidance to the U.S. academic community regarding compliance with export controls and to protect U.S. national security....more
On September 6, the Bureau of Industry and Security (“BIS”) in the U.S. Commerce Department issued an interim final rule (“IFR”) under the Export Administration Regulations (“EAR”) to add new export controls on semiconductor,...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
In its continuing 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 key economic...more
On August 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) announced a series of new measures to further restrict the supply of U.S.-origin and "U.S.-branded" items to Russia and Belarus...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 key economic sanctions imposed by...more
Effective as of June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced several additional export control restrictions and related actions against Russia and Belarus to further...more
On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”) that prohibits U.S....more
On July 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published two (2) new rules in the Federal Register that significantly expand the scope of existing “U.S. Person” prohibitions...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
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a significant new round of sanctions and export...more
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
On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more