News & Analysis as of

Export Controls Penalties

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Mayer Brown

UK Weekly Sanctions Update - Week of May 5, 2025

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In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more

Davis Wright Tremaine LLP

Protect Yourself: U.S. Exporters Advised To Obtain End-Use and End-User Statements for All Exports, Including EAR99 Items

According to a trade press report, a Bureau of Industry and Security ("BIS"), Department of Commerce official speaking at the March 2025 BIS Update Conference on Export Controls and Policy recommended that U.S. exporters...more

Mayer Brown

UK Weekly Sanctions Update - Week of March 17, 2025

Mayer Brown on

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more

ArentFox Schiff

BIS Issues Final Rule for Voluntary Self-Disclosure Procedures

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On Thursday, September 12, 2024, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule updating the agency’s policies on voluntary self-disclosures and the Guidance on Charging and Penalty...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Pillsbury Winthrop Shaw Pittman LLP

New UK Trade Sanctions Enforcement Body Goes Live October 10, 2024

New UK enforcement body goes live and new powers granted to existing body, regulating those doing business in the UK. UK trade sanctions enforcement risks are set to increase on October 10, 2024, as two government agencies...more

Adams & Reese

International Compliance Digest - September 2024

Adams & Reese on

New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

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

Mayer Brown

Teeth Can Bite: Towards Harmonized Rules on EU Sanctions Criminal Enforcement

Mayer Brown on

On March 12, 2023, the European Parliament ("EP") formally endorsed the adoption of a Directive defining criminal offences and penalties for the violation of European Union ("EU") restrictive measures, colloquially known as...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

Foley & Lardner LLP on

Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Torres Trade Law, PLLC

Understanding ITAR Mandatory Disclosures and the “Duty to Inform” DDTC

Torres Trade Law, PLLC on

The discovery of actual or potential International Traffic in Arms Regulations (“ITAR”) violations presents the question of whether to disclose the conduct to the Department of State Directorate of Defense Trade Controls...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

K2 Integrity on

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) published their second Tri-Seal...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

Akerman LLP on

On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Husch Blackwell LLP

BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

Husch Blackwell LLP on

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more

Bass, Berry & Sims PLC

Export Enforcement Update: The Importance of Commodity Classification

Bass, Berry & Sims PLC on

On August 3, 2021, the U.S. State Department Directorate of Defense Trade Controls (DDTC) issued an order laying out charges and imposing a monetary penalty of $6.6 million on Keysight Technologies, a U.S. technology and...more

Perkins Coie

China Enacted the Export Control Law

Perkins Coie on

The Ministry of Commerce of the People’s Republic of China started the multiyear process of enacting a new comprehensive Export Control Law by releasing an initial draft for comment in 2017. Subsequently, following input from...more

Baker Donelson

How China's New Export Control Law May Impact Your Business

Baker Donelson on

On October 17, the Standing Committee of the 13th National People's Congress of the People's Republic of China adopted the Export Control Law of the People's Republic of China (Export Control Law). The new law becomes...more

Pillsbury Winthrop Shaw Pittman LLP

China’s Export Control Law Formally Enacted

The new law establishes a unified export control system. “Export” governed by the law includes not only the transfer of controlled items from within the territory of the PRC to outside of the PRC but also the provision of...more

Perkins Coie

Hong Kong Autonomy Act Signals Significant Shift in US-Hong Kong Relations

Perkins Coie on

The U.S. government on July 14, 2020, took two significant steps to address the evolving situation in Hong Kong. These were primarily in response to the enactment of the Law of the People's Republic of China on Safeguarding...more

A&O Shearman

Airbus Agrees Record-Breaking €3.6 Billion Settlement to Avoid Prosecution

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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

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 2 – The Paper Compliance Program

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus Agrees to Pay $4 Billion in Global Settlement of Foreign Bribery and ITAR Violations (Part I of IV)

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In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more

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