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DOJ Settlement Highlights Customs, FCA Risks for Importers

On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The...more

[Event] Inaugural D.C. Compliance & Government Investigations Seminar - April 8th, Washington, DC

We are pleased to invite you to the inaugural D.C. Compliance & Government Investigations Seminar, hosted by Bass, Berry & Sims in collaboration with Watermark Strategies. This complimentary seminar will build upon the...more

America First Investment Policy Sets Sights on China

On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and...more

Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations

On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil...more

Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty

In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the...more

International Trade Enforcement Roundup – December 2024

You are reading the December 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. - An...more

German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran

Key Points: - Long-arm of U.S. sanctions jurisdiction reaches conduct by European company. - Violation involved shipment to Iran from Australia, a close U.S. ally. On December 3, the Treasury Department’s Office of...more

International Trade Enforcement Roundup – November 2024

You are reading the November 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more

International Trade Enforcement Roundup – October 2024

You are reading the October 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more

Manufacturing & Industrial: Outlooks & Trends

As the manufacturing and industrial sectors continue to embrace digital transformation and navigate complex global markets, the year ahead presents both new opportunities and challenges. From evolving data privacy and AI...more

International Trade Enforcement Roundup – September 2024

What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more

International Trade Enforcement Roundup – Summer 2024

You are reading the Summer 2024 Update of the Bass, Berry & Sims Enforcement Roundup. After a short hiatus, we are back to reporting on notable enforcement actions and policy changes and providing a bit of our insight. -...more

International Trade Enforcement Roundup – April 2024

You are reading the April 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. April saw...more

CFIUS Update: Larger Penalties, Sharper Monitoring

On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more

New Enforcement Plan, Recent Court Filing Can Help Flesh Out UFLPA Obligations

On April 5, the Department of Homeland Security (DHS) announced a plan to crack down on illicit trade in the textile industry. The announcement comes as DHS has been urged, especially by the textile industry, to more...more

International Trade Enforcement Roundup – March 2024 Update

You are reading the March 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. Overview...more

Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations

On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had...more

International Trade Enforcement Roundup – February 2024 Update

February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more

International Trade Enforcement Roundup – January 2024 Update

January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more

International Trade Enforcement Roundup – December 2023 Update

December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

FCPA Enforcement Update: Commodities Trader Agrees to Almost $100 Million Fine

On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation...more

Foreign Corrupt Practices Act Update: Considerations Around Voluntary Disclosures

In September 2022, Deputy Attorney General Lisa Monaco outlined the Department of Justice (DOJ) approach to enforcing corporate misconduct and directed agencies to review existing voluntary self-disclosure policies or, if...more

International Trade Enforcement Roundup – November 2023 Update

You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your...more

FCPA Update: DOJ Opinion Procedure Releases Underscore That Payments to Officials Are Sometimes Permitted

Two recent opinions released by the Department of Justice (DOJ) serve as a reminder that even under the strictly enforced Foreign Corrupt Practices Act (FCPA), payments to government officials are permissible in certain...more

International Trade Enforcement Roundup – October 2023 Update

October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

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