Russia -
Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ)
Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
2/8/2023
/ Banking Sector ,
Bureau of Industry and Security (BIS) ,
California ,
China ,
Conspiracies ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Labor (DOL) ,
Enforcement Actions ,
Espionage ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FBI ,
FCPA Corporate Enforcement Policy (CEP) ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Iran Sanctions ,
Money Laundering ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Self-Disclosure Requirements ,
Venezuela
Russia -
Active Russian Agent Indicted for Scheme to Violate Sanctions in the United States (DOJ Action)
Those involved. Andrii Derkach, a Ukrainian national and – according to the DOJ – an “Active Russian Agent.”...more
1/13/2023
/ China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Securities and Exchange Commission (SEC) ,
Settlement
You are reading Bass, Berry, & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.
...more
12/9/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Illegal Imports ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Secrets
There have been a relatively limited number of U.S. Foreign Corrupt Practices Act (FCPA) enforcement actions in recent years. Nonetheless, two recent announcements (one resolution, one declination) by U.S. regulators...more
• The World Bank aggressively pursues sanctions against entities and individuals for misconduct in connection with Bank-funded projects
• Sanctions can lead to cross-debarment by other multilateral development banks and...more
• Previously permissible activities must be wound down in 90 or 180 days
• Non-U.S. companies at particular risk of enforcement action
• Only limited guidance issued so far, unclear what authority U.S. companies...more
•Many medical products can be exported to Iran – so long as a license is obtained
•Imposition of successor liability underscores importance of pre-transaction due diligence
•OFAC enforcement, as in the past, continues...more
1/10/2018
/ Aggravating Factors ,
Distributors ,
Due Diligence ,
Enforcement Actions ,
Exports ,
Iran Sanctions ,
Licenses ,
Manufacturers ,
Medical Supplies ,
Mergers ,
Mitigating Factors ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanction Violations ,
Statute of Limitations ,
Subsidiaries ,
Successor Liability ,
Voluntary Disclosure
It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more
6/24/2017
/ Administrative Procedure Act ,
Appeals ,
Arbitrary and Capricious ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Remand ,
Sanction Violations ,
Subpoenas