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)
The Group of Seven (“G7”) has taken a critical step in bolstering its collective enforcement of export controls and sanctions against the Russian Federation by issuing a historic joint industry guidance document. This move is...more
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 July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...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 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
The sheer proliferation of supply chain transparency and accountability regulations at international scale itself warrants a closer look at the level of scrutiny required of organizations with complex, multi-faceted, global,...more
3/7/2024
/ Audits ,
Compliance ,
Due Diligence ,
Exploitation ,
Export Controls ,
Forced Labor ,
Human Rights ,
Regulatory Oversight ,
Risk Management ,
Suppliers ,
Supply Chain ,
Sustainability ,
Third-Party Service Provider ,
Transparency
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
New guidance from the Biden Administration mandates that freight forwarders are responsible for complying with trade sanctions and export compliance. On December 11, 2023, the Biden Administration released a 10-page sanctions...more
12/19/2023
/ Biden Administration ,
Compliance ,
Export Controls ,
Exporters ,
Exports ,
Freight Forwarding ,
Goods or Services ,
Motor Carriers ,
New Guidance ,
Risk Mitigation ,
Shipping ,
Shipping Cargo ,
Supply Chain ,
Trucking Industry ,
US Trade Policies ,
Vessels ,
WMD
As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more
12/8/2023
/ Compliance ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Failure to Comply ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Foreign Trade Regulations ,
Russia ,
Sanction Violations ,
Semiconductors ,
Ukraine
On November 3, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that a settlement had been reached with Forta —a domestic synthetic fiber manufacturer—for its conduct in agreeing to a...more
On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a new joint notice concerning...more
11/27/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Control Reform (ECR) ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Policy ,
Foreign Relations ,
Joint Statements ,
Popular ,
Russia ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
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