Sanction and the Increasing Complexity of Trade Compliance
On September 30, 2024, Quantum Corporation—a U.S.-based technology company— reached a settlement with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) to resolve 45 separate violations of the...more
On July 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released an updated version of Don’t Let This Happen To You!, which contains summaries of actual investigations of Export Control and...more
As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more
In Husch Blackwell’s June 2024 Trade Law Update you’ll learn about the following updates in international trade and supply chain law: •An update on U.S. Department of Commerce decisions - •U.S. International Trade...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
The Office of Antiboycott Compliance (“OAC”) within the U.S. Department of the Treasury’s Bureau of Industry and Security (“BIS”) is charged with administering and enforcing the Anti-Boycott Act of 2018, Part II of the Export...more
Ford Motor Company Agrees to $365M Settlement for Attempted Tariff Engineering Ford has agreed to settle the long-standing dispute over the tariff classification of vans imported from 2009 to 2013. At the time, Customs and...more
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
The Bureau of Industry and Security (BIS) has recently published a guidance document on its new website aimed at helping freight forwarders and exporters uphold compliance with U.S. export controls and regulatory...more
We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
Anti-boycott rules are one of the lesser raised issues across clients involved in international trade or in servicing those movements, but the issue does arise. The rules originated in the Export Administration Act of 1979...more
On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and relatively rare enforcement action...more
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
On July 26, 2023, Matthew Axelrod, the Assistant Secretary for Export Enforcement, issued a memorandum on “Strengthening Antiboycott Reporting and Compliance.” The memorandum announced two new measures. First, the Commerce...more
Tucked away between the many export-focused provisions of the Export Administration Regulations ("EAR") is the easily overlooked Part 760, which addresses "Restrictive Trade Practices or Boycotts." It is comprised of (1)...more
With the proliferation of sanctions in the wake of the war in Ukraine and more focus on responsible sourcing, trade compliance has grown exponentially in complexity. It has also become less of a compliance silo and become...more
Background - U.S. antiboycott laws, which are divided into two separate regimes administered by the U.S. Department of Commerce and the U.S. Department of the Treasury, prohibit U.S. persons from participating in foreign...more
The U.S. Department of the Treasury has removed the United Arab Emirates from its latest "List of Countries Requiring Cooperation With an International Boycott," easing certain tax reporting requirements. On April 8, 2021,...more
Key Points - On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more
On April 8, 2021, the U.S. Department of the Treasury (Treasury), which administers an antiboycott law and associated guidelines in response to the Arab League’s boycott of Israel, published an updated list of boycotting...more
An often overlooked, but potentially substantial risk factor in a company’s export compliance strategy is the degree to which the company is both familiar with—and adheres to—U.S. Departments of Treasury and Commerce...more
Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more
On March 14, 2018, the House Committee on Foreign Affairs held a hearing titled “Modernizing Export Controls: Protecting Cutting Edge Technology and U.S. National Security” to examine the proposed Export Control Reform Act...more