In the nearly eighteen months since the Russian invasion of Ukraine, many companies have had to reanalyze their export control compliance procedures, particularly with respect to countries with adversarial or strained...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
In a burst of activity, the US Department of Commerce, Bureau of Industry and Security (BIS) issued two final rules and one proposed rule. These rules, published in the Federal Register on April 28, 2020, made a series of...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
On November 7, 2014, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) announced a final rule implementing controls on exports, re-exports and transfers of a variety of goods, software and technologies for...more