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
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations...more
1/10/2025
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
Sanction Violations ,
U.S. Commerce Department
On November 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $500,000 monetary penalty on GlobalFoundries U.S. 2 LLC and its parent, GlobalFoundries U.S. Inc., for a series of...more
11/6/2024
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Manufacturers ,
Popular ,
Semiconductors ,
Statutory Violations
On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued critical guidance aimed at enhancing financial institutions’ compliance with the Export Administration Regulations (“EAR”)....more
On September 30, 2024, Quantum Corporation—a U.S.-based technology company— reached a settlement with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) to resolve 45 separate violations of the...more
10/9/2024
/ Antiboycott Requirements ,
Boycotts ,
Bureau of Industry and Security (BIS) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Popular ,
Regulatory Violations ,
Settlement ,
Strict Liability ,
United Arab Emirates (UAE)
On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational...more
9/6/2024
/ Corporate Counsel ,
Corruption ,
Defense Sector ,
Department of Defense (DOD) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
ITAR ,
Statutory Violations ,
White Collar Crimes
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
On July 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published two (2) new rules in the Federal Register that significantly expand the scope of existing “U.S. Person” prohibitions...more
On June 24, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the settlement of an administrative enforcement action involving Indiana University of Bloomington (“Indiana University”)...more
On June 14, 2024, U.S. Department of Commerce Assistant Secretary for Export Enforcement, Matthew Axelrod, officially issued an order activating the suspended portion of a civil penalty that was imposed on U.S-based freight...more
6/26/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Civil Monetary Penalty ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Regulatory Violations ,
Settlement Agreements ,
U.S. Commerce Department ,
United Arab Emirates (UAE)
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
6/12/2024
/ Airbus ,
Antiboycott Requirements ,
Boycotts ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Defense Sector ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Popular ,
Statutory Violations ,
U.S. Commerce Department
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
On April 29, 2024, the U.S. Department of Commerce officially published a final rule in the Federal Register that formally incorporates a medical device license exception into the Export Administration Regulations (“EAR”) for...more
5/16/2024
/ Belarus ,
Commodities ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Healthcare ,
Licensing Rules ,
Medical Devices ,
New Rules ,
Russia ,
U.S. Commerce Department ,
Ukraine
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
On April 19, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) that officially codifies certain changes to the Export Administration Regulations (“EAR”)...more
Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the...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
2/8/2024
/ Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corruption ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Regulatory Violations ,
US Trade Policies
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 global political tensions continued to escalate on multiple fronts, the 2023 calendar year saw a noticeable increase in the number of enforcement actions initiated by the U.S. government against entities and individuals...more
Recent comments from the top leadership of both the Directorate of Defense Trade Controls (“DDTC”) and Bureau of Industry and Security (“BIS”) during a government and defense industry conference last week should give all...more
11/10/2023
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Compliance ,
Data Management ,
Directorate of Defense Trade Controls (DDTC) ,
Export Administration Regulations (EAR) ,
Export Controls ,
ITAR ,
Misclassification ,
Technical Standards ,
US Trade Policies
On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and relatively rare enforcement action...more
9/13/2023
/ Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corruption ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Popular ,
US Trade Policies