ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more
Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more
As many of you are aware, with some minor exceptions, the United States bifurcates export controls responsibility between the Department of State, which administers the International Traffic in Arms Regulations (the “ITAR”),...more
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more
On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a...more
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
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing policies that favor such disclosure by...more
On April 18, 2023, the U.S. Department of Commerce (“Commerce”)’s Assistant Secretary for Export Enforcement issued a Memorandum titled “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning...more
Since the Russian invasion of Ukraine in February 2022, the U.S. government has made it increasingly clear that enforcement of export control and economic sanctions laws is a top priority. From launching task forces to target...more
On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more
On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) released a set of “policy clarifications” in the context of a memorandum authored by the...more
Continuing the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) efforts to bolster enforcement and compliance, on April 18, 2023, BIS issued a memorandum announcing significant changes to its voluntary...more
In a memorandum published by the Bureau of Industry and Security on April 18, 2023, the Office of Export Enforcement (OEE) announced that it wants to incentivize voluntary self-disclosures (VSDs) after a party uncovers...more
Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations....more
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
When most people think of exports, they imagine the movement of merchandise across international borders. However, an export can happen without having to leave the United States, such as in your office breakroom, by storing...more
On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more