News & Analysis as of

Export Controls Voluntary Disclosure Export Administration Regulations (EAR)

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

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

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

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

Alston & Bird

BIS Powers Up Its Voluntary Self-Disclosure Process and Penalty Guidelines

Alston & Bird on

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

Troutman Pepper Locke

BIS Issues Key Updates to the ‎Voluntary Self-Disclosure Process ‎and Penalty Guidelines

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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

Torres Trade Law, PLLC

BIS Tightens Export Control Enforcement

Torres Trade Law, PLLC on

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

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

Dechert LLP

BIS Enhances Its Voluntary Self-Disclosure Process and Related Enforcement Guidance

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (the “Rule”) regarding changes to the provisions of the Export Administration Regulations (the “EAR”) governing voluntary...more

The Volkov Law Group

DXC Technology Company Settles Sanctions and Export Control Violations

The Volkov Law Group on

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

Morrison & Foerster LLP

Tri-Seal Compliance Note Stresses Importance of Non-U.S. Persons Complying with U.S. Sanctions and Export Control Laws

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

Torres Trade Law, PLLC

U.S. Government to Foreign Persons: Comply with Economic Sanctions and Export Control Laws

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

Braumiller Law Group, PLLC

Braumiller Law Group & Braumiller Consulting Group February 2024 newsletter

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

Braumiller Law Group, PLLC

Hot Topics in International Trade - February 2024 - BIS Unveils Enhanced Voluntary Self Disclosure Protocols

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

The Volkov Law Group

BIS Announces Further Enhancements to Voluntary Self-Disclosure Process

The Volkov Law Group on

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

Vinson & Elkins LLP

BIS Streamlines Voluntary Self-Disclosure Requirements, But Exporters Should Carefully Evaluate Before Using This Process

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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

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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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

Foodman CPAs & Advisors

Nota De Cumplimiento Del BIS, DOJ Y OFAC

Foodman CPAs & Advisors on

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

Foodman CPAs & Advisors

Compliance Note From BIS, DOJ & OFAC

Foodman CPAs & Advisors on

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

Troutman Pepper Locke

Joint Compliance Note Issued by ‎Departments of Justice, ‎Commerce and Treasury on Voluntary ‎‎Self-Disclosure of ‎Potential...

Troutman Pepper Locke on

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

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

Hogan Lovells

U.S. agencies signal reinforced export enforcement collaboration and partnership

Hogan Lovells on

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

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (June 21, 2023)

Foley & Lardner LLP on

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

Womble Bond Dickinson

U.S. Commerce Department Incentivizes Disclosures of Export Control Violations

Womble Bond Dickinson on

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

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

A&O Shearman

Commerce Raises Enforcement and Compliance Profile

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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

Venable LLP

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

Venable LLP on

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

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