New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more
10/2/2024
/ Anti-Bribery ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Interim Final Rules (IFR) ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Securities and Exchange Commission (SEC) ,
USTR ,
Voluntary Disclosure ,
Whistleblowers
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
9/10/2024
/ Antiboycott Requirements ,
Arms Export Control Act ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Compliance ,
Corporate Crimes ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Exports ,
Forced Labor ,
Healthcare Fraud ,
Incentives ,
International Trade ,
Investment ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Russia ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Voluntary Disclosure ,
Whistleblowers
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
8/1/2024
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Compliance ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Forced Labor ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List
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
7/2/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List
May saw the long-awaited release of the USTR’s Section 301 review. USTR confirmed that the Trump-era tariffs will remain in place, and raised those tariffs by another $18 billion on manufacturing, critical minerals, solar...more
6/4/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Electric Vehicles ,
Enforcement ,
Forced Labor ,
Manufacturers ,
Minerals ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Self-Disclosure Requirements ,
Solar Panels ,
Tariffs ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA)
International Compliance Digest is the new Adams and Reese monthly newsletter focused on international trade compliance and enforcement. Each month we will bring you the latest in compliance and enforcement updates, including...more
4/5/2024
/ Anti-Bribery ,
Anti-Corruption ,
Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Noncompliance ,
Office of Foreign Assets Control (OFAC) ,
Trade Relations ,
U.S. Commerce Department
On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more
3/13/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Commodity Trading Advisors (CTAs) ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disgorgement ,
Economic Sanctions ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Global Marketplace ,
Penalties ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Tariffs ,
Trade Relations ,
Trade Restrictions ,
Whistleblowers