Author: Alex Cotoia

10 Oct, 2024

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property management and concierge company—for serial breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The enforcement action followed an extensive investigation that uncovered ICSL’s involvement in facilitating payments linked to a designated individual subject...

General

8 Oct, 2024

BIS Reaches $151,875 Settlement with Quantum Corporation Over Violations of the EAR’s Antiboycott Provisions

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 antiboycott provisions of the Export Administration Regulations (“EAR”). The antiboycott provisions of the EAR are a critical component of U.S. export control regulations designed to prevent U.S. businesses from participating in or supporting foreign...

General

30 Sep, 2024

G7 Announces Joint Initiative to Combat Russian Sanctions and Export Control Evasion

The Group of Seven (“G7”) has taken a critical step in bolstering its collective enforcement of export controls and sanctions against the Russian Federation by issuing a historic joint industry guidance document. This move is not merely a procedural update; it represents a concerted effort by the G7—comprising the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom—to address the sophisticated evasion tactics...

General

11 Sep, 2024

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the Foreign Corrupt Practices Act (“FCPA”). These violations arose from improper activities undertaken by its wholly owned subsidiary, Wirtgen Thailand. The underlying misconduct—which occurred between late 2017 and 2020—included the provision of illicit payments and other...

General

5 Sep, 2024

RTX Corporation Reaches Record $200 Million Settlement with DDTC for Serial Violations of the AECA and ITAR

On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational aerospace and defense conglomerate—for 750 separate violations of the Arms Export Control Act (“AECA”) and accompanying International Traffic in Arms Regulations (“ITAR”). As described in the context of a charging letter released by DDTC, RTX Corporation...

General

22 Aug, 2024

BIS Reaches Settlement of $5.8 Million Enforcement Action with TE Connectivity Corporation over Export of EAR99 Commodities

On August 15, 2024, the U.S. Department of Commerce’s Office of Export Enforcement (“OEE”) announced the settlement of the latest administrative enforcement action involving TE Connectivity Corporation—a Pennsylvania-based electronics company—and its affiliate, TE Connectivity Hong Kong Limited (collectively, “TE Connectivity”), for their involvement in seventy-nine (79) separate violations of the Export Administration Regulations (“EAR”) arising from a series of unlicensed EAR99 exports made to Entity...

General

13 Aug, 2024

BIS Publishes Proposed Revisions to EAR Addressing U.S. Person Support for “Foreign Security” and Military End Users

On July 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published two (2) new rules in the Federal Register that significantly expand the scope of existing “U.S. Person” prohibitions currently in existence under the Export Administration Regulations (“EAR”) to encompass support activities that relate to both newly defined “foreign-security” end users as well as certain redefined “military” end users. The rules—introduced...

General

7 Aug, 2024

EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent

On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations (also known as “restrictive measures”) adopted by the EU to advance critical foreign policy objectives—including, but not limited to, the EU’s ongoing support for Ukraine against Russian Federation aggression. The issuance of...

General

16 Jul, 2024

OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings

On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign Activities Sanctions regime. The updated designations for the entities—all of which are referenced on either OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”) or the Sectoral Sanctions Identifications...

General

9 Jul, 2024

BIS Announces Settlement Agreement with Indiana University Over Export Control Violations

On June 24, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the settlement of an administrative enforcement action involving Indiana University of Bloomington (“Indiana University”) over multiple violations of export controls spanning a four-year period. According to the settlement agreement publicized by BIS, Indiana University illegally exported genetically modified strains of fruit flies containing transgenes of a certain subunit of...

Author: Alex Cotoia

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

BIS Reaches $151,875 Settlement with Quantum Corporation Over Violations of the EAR’s Antiboycott Provisions

G7 Announces Joint Initiative to Combat Russian Sanctions and Export Control Evasion

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

RTX Corporation Reaches Record $200 Million Settlement with DDTC for Serial Violations of the AECA and ITAR

BIS Reaches Settlement of $5.8 Million Enforcement Action with TE Connectivity Corporation over Export of EAR99 Commodities

BIS Publishes Proposed Revisions to EAR Addressing U.S. Person Support for “Foreign Security” and Military End Users

EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent

OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings

BIS Announces Settlement Agreement with Indiana University Over Export Control Violations

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