This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more
4/18/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
US Trade Policies ,
White Collar Crimes
U.S. authorities have been active in November 2023, reinforcing and expanding sanctions targeting Russia's war effort in Ukraine. Multiple agencies added sanctions targeting entities involved in Russia's military supply...more
As the standoff in Congress on the budget threatens to shut down vast swaths of the federal government, we write to remind clients about how a federal government shutdown would affect international trade and investment. The...more
10/2/2023
/ Appropriations Bill ,
Bureau of Industry and Security (BIS) ,
Census Bureau ,
CFIUS ,
Customs and Border Protection ,
Enforcement Actions ,
Federal Budget ,
Federal Funding ,
Government Shutdown ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
U.S. Commerce Department
On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more
8/3/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Crimes ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
On April 28, 2023, U.S. Attorney for the District of Massachusetts Rachel Rollins, joined by national and local federal enforcement officials from the Disruptive Technology Strike Force (DTSF), described the DTSF mission and...more
The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more
4/21/2023
/ Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Financial Services Industry ,
Foreign Direct Investment ,
Human Rights ,
International Trade ,
Iran ,
National Security ,
Nicaragua ,
Russia ,
Trade Restrictions ,
U.S. Commerce Department ,
UK ,
US Department of State ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)
June 23, 2022 Key Takeaways: In two recent speeches, Matthew Axelrod, Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (“BIS”), has signaled policy changes related to...more
6/23/2022
/ Antitrust Violations ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Sanctions ,
Self-Disclosure Requirements ,
U.S. Commerce Department
BIS Imposes New Export Controls on Certain Industrial EAR99 Items -
Currently, all items on the Export Administration Regulations’ (“EAR“) Commerce Control List (“CCL”) require a license for export, re-export or transfer...more
6/14/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
Key Takeaways:
• U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
• Actions targeting the defense sector and Russian government-affiliated media...more
3/8/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Financial Transactions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
Ukraine
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
2/25/2022
/ Afghanistan ,
Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Burma ,
Cambodia ,
CFIUS ,
China ,
Cuba ,
Economic Sanctions ,
Enforcement ,
Ethiopia ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Human Rights ,
International Criminal Court ,
Iran Sanctions ,
ITAR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Myanmar ,
Nicaragua ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Sudan ,
U.S. Treasury ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela ,
Virtual Currency ,
Withhold Release Orders (WROs)
In response to a request from the ranking member of the House Foreign Affairs Committee, the Department of Commerce’s Bureau of Industry and Security (BIS) provided export license statistics related to Chinese firms Huawei...more
Sales of your software are robust around the globe. You have a network of third-party resellers, distributors or implementation partners that are driving international growth. Your customers praise your efficient maintenance...more
5/20/2021
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Department of Justice (DOJ) ,
Export Controls ,
Germany ,
Investigations ,
Iran ,
Iran Sanctions ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SAP SE ,
Settlement ,
Software ,
Voluntary Disclosure
This is the second in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed SEC enforcement. Up next,...more
3/17/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
China ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
Fraud ,
Imports ,
Iran ,
Popular ,
Russia ,
Sanctions ,
Trump Administration ,
Venezuela
Hong Kong Updates and Alerts -
New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended -
On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...more
8/7/2020
/ 5G Network ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
CFIUS ,
China ,
Cross-Border ,
Cuba ,
Department of Justice (DOJ) ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
FCPA Resource Guide ,
Final Rules ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Huawei ,
International Chamber of Commerce (ICC) ,
Iran Sanctions ,
Military End Use ,
New Rules ,
Nicaragua ,
Russia ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
State-Owned Enterprises ,
Syria ,
Trump Administration ,
Venezuela
Huawei Charged in Racketeering Conspiracy and Conspiracy to Steal Trade Secrets; Temporary General License Extended –
On February 13, 2020, Huawei Technologies Co. Ltd. (Huawei) and two of its U.S. subsidiaries were...more
3/17/2020
/ Airbus ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Criminal Conspiracy ,
Criminal Prosecution ,
Cross-Border ,
Cross-Border Transactions ,
Economic Sanctions ,
General Licenses ,
Huawei ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Transitional Arrangements ,
U.S. Treasury ,
UK ,
UK Brexit ,
Venezuela
New CFIUS Regulations Released: Final Rules Impact Foreign Investment in Technology, Infrastructure, and Data (TID) Businesses and Real Estate -
On January 13, 2020, the Department of the Treasury issued final regulations...more
2/6/2020
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Investment ,
Office of Foreign Assets Control (OFAC) ,
Technology Sector
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
1/24/2020
/ Bureau of Industry and Security (BIS) ,
Chief Compliance Officers ,
China ,
Compliance ,
Corporate Counsel ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Hong Kong ,
Huawei ,
Human Rights ,
Information Technology ,
Iran Sanctions ,
Magnitsky Act ,
National Security ,
New Guidance ,
New Regulations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Software ,
Syria ,
Technology Sector ,
Turkey ,
U.S. Treasury ,
US Department of State ,
Venezuela ,
Voluntary Disclosure ,
White Collar Crimes
On Monday, April 16, 2018, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was imposing a denial of export privileges against Zhongxing Telecommunications Equipment Corporation of...more