In one of the most significant enforcement actions involving the illicit export of aircraft components to Russia since the imposition of sweeping sanctions in response to the country’s invasion of Ukraine, the U.S. Department...more
While the incoming administration has blanketed the news cycle with newly threatened tariffs against typical targets like China, and against neighboring allies like Canada and Mexico, the current administration has quietly...more
With federal elections and the conclusion of the 118th Congress drawing near, “China Week,” as dubbed by House leadership, presented one of the final opportunities for the US House of Representatives to act on a variety of...more
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more
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
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
Five US senators recently introduced legislation that would amend US export control laws to protect sensitive personal data. The bipartisan bill, titled the Protecting Americans’ Data from Foreign Surveillance Act of 2022,...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
The Justice Department is often criticized for its lack of transparency. But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it....more
On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more
Our International Trade & Regulatory and White Collar, Government & Internal Investigations Groups review the Justice Department’s revised voluntary self-disclosure policy and find that it is a welcome change for companies...more
For several years, we have witnessed the emergence of a statutory and regulatory framework to tighten controls on the export of emerging and critical technology, as well as the review of inward foreign investment into said...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
On December 3, 2019, the U.S. Department Justice (DOJ) announced charges against two Russian nationals, two Italian nationals, a U.S. citizen, and various companies for violating and conspiring to violate the International...more
Tariffs targeting Chinese imports into the United States garnered headlines throughout 2018. However, during the latter part of the year, the U.S. government more quietly initiated efforts that in 2019 and beyond could be...more