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
4/1/2025
/ China ,
Corporate Counsel ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Imports ,
Settlement ,
Tariffs ,
Trump Administration ,
Whistleblowers
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
3/3/2025
/ CFIUS ,
China ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Investment ,
International Trade ,
Investment ,
Legislative Agendas ,
National Security ,
Regulatory Agenda ,
Technology Sector ,
Trump Administration
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
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
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
3/15/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Employees ,
Entity List ,
Exports ,
Foreign Persons ,
Fraud ,
Iran ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Technology ,
U.S. Treasury ,
UK ,
Ukraine
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
2/8/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
United Arab Emirates (UAE)
August saw two noteworthy Russia-related enforcement actions. First, a dual Russian-German national was arrested and charged with violating the Export Control Reform Act (ECRA) when he allegedly procured microelectronics for...more
9/11/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Convictions ,
Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Discrimination ,
Elon Musk ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
ITAR ,
Money Laundering ,
Russia ,
SpaceX ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Whistleblowers
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
8/17/2023
/ Antiboycott Requirements ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Foreign Entities ,
Foreign Nationals ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
You are reading the June 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 inbox.
- June saw...more
7/12/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Ghana ,
International Litigation ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sudan ,
Uyghur Forced Labor Prevention Act (UFLPA)
May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian...more
6/23/2023
/ Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Enforcement ,
Entity List ,
EU ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Secrets ,
U.S. Commerce Department
You are reading the April 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 inbox.
-We saw...more
5/25/2023
/ China ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
International Trade ,
Iran ,
North Korea ,
Russia
Russia -
Russian National Charged with Supplying U.S. Technology to the Russian and North Korean Governments (DOJ Action)
Those involved. Ilya Balakaev, Russian national.
Charges and penalties. Conspiracy to...more
3/16/2023
/ 3D Printing ,
Antitrust Violations ,
Austria ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Justice (DOJ) ,
Drones ,
E-Commerce ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Claims Act (FCA) ,
FBI ,
Iran ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Smuggling ,
Switzerland ,
U.S. Treasury ,
Ukraine
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
On August 3, 2021, the U.S. State Department Directorate of Defense Trade Controls (DDTC) issued an order laying out charges and imposing a monetary penalty of $6.6 million on Keysight Technologies, a U.S. technology and...more
8/20/2021
/ China ,
Commodities ,
Consent Agreements ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
ITAR ,
Penalties ,
Russia ,
Software ,
Technology
The U.S. Treasury Department, Office of Foreign Assets Control (OFAC), the main U.S. government body that administers U.S. economic sanctions and embargoes, continues to be busy. In September 2019 alone, OFAC has announced...more
9/27/2019
/ China ,
Economic Sanctions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Settlement Agreements ,
Sudan ,
Trade Relations ,
Trump Administration ,
Unfair or Deceptive Trade Practices ,
Venezuela
• Company committed multiple apparent violations of U.S. sanctions on North Korea
• Penalty imposed in part because of company’s “non-existent” sanctions compliance program
• Settlement underscores need to address supply...more
2/8/2019
/ China ,
Corporate Counsel ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Settlement Agreements ,
Supply Chain
• 7-year denial order imposed against Chinese telecommunications equipment maker
• Denial order strictly limits business with company
• Action comes as U.S. imposes other trade restrictions on China
On April 16, U.S....more
4/23/2018
/ CFIUS ,
China ,
Economic Sanctions ,
Export Controls ,
Exports ,
Mergers ,
National Security ,
Sanction Violations ,
Semiconductors ,
Telecommunications ,
Trump Administration
On March 12, 2018, President Trump blocked Broadcom, a Singapore-based semiconductor manufacturer, from pursuing the purchase of U.S.-based Qualcomm, a rival chip maker. Broadcom’s offer, reportedly for $117 billion or...more
This Post at a Glance -
- Company made false statements related to import duty charges
- Investigation initiated by whistleblower complaint from company’s competitor
- Trump Administration likely to impose...more
2/21/2018
/ Anti-Dumping Duty ,
China ,
Countervailing Duties ,
Customs ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
False Statements ,
Fraud ,
Furniture Industry ,
Government Investigations ,
Imports ,
Settlement Agreements ,
Tariff Classifications ,
Trump Administration ,
Underpayment ,
Unfair or Deceptive Trade Practices ,
Whistleblower Awards ,
Whistleblowers
- MoneyGram and Ant Financial mutually terminate $1.2 billion proposed merger
- CFIUS’s concerns focused on cyber and information security
- Scrutiny of buyers’ information security processes is likely to increase
On...more
1/22/2018
/ Acquisitions ,
CFIUS ,
China ,
Cross-Border Transactions ,
Cybersecurity ,
Data Security ,
Foreign Investment ,
Mergers ,
Moneygram ,
National Security ,
Technology Sector ,
Trump Administration
More Acquisitions May Be Blocked in the Future -
Last month, asserting national security concerns, President Trump blocked a $1.3 billion acquisition of Oregon-based Lattice Semiconductor by a subsidiary of the Canyon...more
On March 7, 2017, Chinese telecommunications company, Zhongxing Telecommunications Equipment Corp. (ZTE), signed on to three separate settlement agreements with the United States, agreeing to pay $892 million for violations...more