News & Analysis as of

U.S. Commerce Department Sanction Violations

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

The Volkov Law Group

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations...more

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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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

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

WilmerHale

OFSI Encourages Self-Reporting of Sanctions Breaches

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Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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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

Akin Gump Strauss Hauer & Feld LLP

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

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On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Eversheds Sutherland (US) LLP

BIS imposes historic settlement for alleged Huawei-related violations of the Entity List Foreign Direct Product Rule

On April 19, 2023, the US Department of Commerce Bureau of Industry and Security (BIS) entered into a settlement agreement wherein Seagate Technology LLC and Seagate Singapore International Headquarters Pte. Ltd....more

The Volkov Law Group

Bureau of Industry and Security Extracts $300 Million Fine Against Seagate Technology for Violation of Huawei Prohibition

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Matt Axelrod, the Assistant Secretary for Export Enforcement, at the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, must be grinning with satisfaction that BIS delivered, in a big way, after he...more

Latham & Watkins LLP

US Agencies Issue Joint Compliance Note on Russia-Related Sanctions and Export Controls Evasion

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The first-ever tri-seal Note highlights tactics used to circumvent Russia-related restrictions, while NSD adds 25 prosecutors focusing on sanctions and export controls. In May 2022, shortly after hostilities in Ukraine...more

The Volkov Law Group

DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls

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As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more

Katten Muchin Rosenman LLP

US Moves to Seize Aircraft for Apparent Violation of Export Controls

Key Points - - The US Department of Justice reported that it obtained a warrant for the seizure of a Boeing 737-7EM aircraft for the alleged violation of US export controls on Russia (rather than because of ownership of...more

Lowenstein Sandler LLP

Trade Matters - October 2021

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1. Expanded Export Controls on Certain Biological Equipment Software Are Coming- As part of the Bureau of Industry and Security’s emerging and foundational technology control effort, new export controls are forthcoming...more

Skadden, Arps, Slate, Meagher & Flom LLP

Commerce Department’s New Export-Related Restrictions Inhibit Semiconductor Design by and Manufacturing for Huawei

In response to the announcement on Friday by the U.S. Department of Commerce of new export-related restrictions targeting Huawei Technologies Co., Ltd. and several of its non-U.S. affiliates (collectively, Huawei), Sen. Ben...more

Society of Corporate Compliance and Ethics...

Indictment for export of dual-use item to Libya

Report on Supply Chain Compliance 2, no. 21 (November 7, 2019) - The U.S. Department of Justice indicted Peter Soti for alleged violations of the International Emergency Economic Powers Act and the Export Administration...more

Holland & Knight LLP

The Drama Around Huawei: Can U.S. Companies Do Business with the Chinese Chipmaker? - Huawei Seems to Be a Bargaining Chip in...

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• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Department Signs New Agreement with ZTE Lifting Denial Order in Exchange for Unprecedented Additional Penalties and...

• On June 11th, BIS published a superseding settlement agreement with ZTE, levying the largest-ever monetary penalty by BIS against a non-U.S. company and imposing significant additional compliance measures in exchange for...more

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