ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
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, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty of $151,875 against a U.S.-based technology company to resolve 45 alleged violations of the antiboycott...more
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
Sanctions imposed by the United States, the United Kingdom, and the European Union against Russia, China, and other parts of the world are fast-evolving. Such geopolitical shifts are creating new risks and placing further...more
On August 15, 2024, the U.S. Department of Commerce’s Office of Export Enforcement (“OEE”) announced the settlement of the latest administrative enforcement action involving TE Connectivity Corporation—a Pennsylvania-based...more
The risks for international investments have sharply expanded in recent years. Identifying, managing, and mitigating investment risk, in the current regulatory environment, can be just as essential as managing risk in any...more
July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more
On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more
Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more
On June 3, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the resolution of an administrative enforcement action brought against Airbus DS Government Solutions (“Airbus DSGS”)—a...more
On May 15, 2024, the U.S. Commerce Department’s Bureau of Industry and Security issued an antiboycott compliance advisory regarding the Turkish government’s announcement that it will suspend all imports and exports to and...more
On March 28, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released updated guidance to freight forwarders specifically outlining their responsibilities under the aegis of the Export...more
License Exception MED, published by the US Department of Commerce’s Bureau of Industry and Security (BIS) on April 25, authorizes the export, reexport, or in-country transfer of EAR99 “medical devices” to non-military...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
Since President Biden issued his Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, the U.S. Patent and Trademark Office has been investigating the potential pitfalls of...more
On March 28, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) published a new resource for companies, freight forwarders, financial institutions, and others to help them comply with the U.S....more
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
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
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
I. US SANCTIONS - US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more
Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more
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
On February 7, the U.S. Department of Justice (DOJ) announced that settlements and judgements under the False Claims Act (FCA) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the second-highest...more
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
As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more