Category: General

30 May, 2024

DXC Technology Company Settles Sanctions and Export Control Violations

On May 17, 2024, Nevada-based DXC Technology Company (“DXC”)—a global IT services provider—officially filed its required annual 10-K Form with the U.S. Securities and Exchange Commission (“SEC”) indicating that previously-disclosed proceedings involving both the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) had been resolved. According to the SEC filing, DXC officially...

General

29 May, 2024

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls enforcement and focuses on China trade. The Act: The Act amends the statute of limitations for International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) to ten...

General

28 May, 2024

Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme

Sigma-Aldrich, Inc., d/b/a MilliporeSigma (“MilliporeSigma”), a U.S. life sciences company based in Massachusetts, escaped criminal charges for export control violations, despite a former sales person’s scheme to illegally export products to China. DOJ cited the favorable resolution as proof of the National Security Division’s commitment to its voluntary disclosure program. MilliporeSigma was the first company to resolve an investigation for export control violations under DOJ/NSD’s...

Uncategorized

27 May, 2024

DOJ Antitrust Division Launches New Task Force on Health Care Monopolies and Collusion

The U.S. Department of Justice’s Antitrust Division has intensified its scrutiny of healthcare platforms that integrate doctors with insurers, data, and other assets. Assistant Attorney General Jonathan Kanter described this trend as an “alarming” concentration of resources. In a significant move, the DOJ announced the establishment of the Task Force on Health Care Monopolies and Collusion. Kanter emphasized during a Washington Post Live event that...

General

24 May, 2024

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason — geography is an important limiter on sanctions risks. The ability to evade sanctions has to be financially practicable — for example, it makes no sense to...

General

22 May, 2024

Supply Chain and Sanctions Compliance (Part III of IV)

While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale and distribution of products to ultimate users does not appear to be unreasonable or impractical. In terms of best practices, these are issues that need to be addressed. The supply chain and third-party risk...

General

21 May, 2024

Distribution Chains and Sanctions Compliance (Part II of IV)

Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment. Additionally, companies may maintain parallel sales activities in markets between their own sales staff and third-party distributors, agents, resellers and dealers. It is interesting how certain industries have evolved and relied on different models for use of third parties with the intent of reaching customers in...

General

20 May, 2024

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965 — Video Here). So, how does that relate to third-party risks? Well, bear with me here for a little. Legal and Compliance bloggers, compliance vendors, prognosticators, Compliance Podcasters, and everyone in the Paparazzi have written,...

General

16 May, 2024

Commerce Department Promulgates New Rule Adopting Medical Device License Exception for EAR99 Exports to Russia, Belarus and Ukraine

On April 29, 2024, the U.S. Department of Commerce officially published a final rule in the Federal Register that formally incorporates a medical device license exception into the Export Administration Regulations (“EAR”) for certain commodities bound for the Russian Federation, Belarus, and occupied regions of Ukraine. New license exception MED—located at 15 C.F.R. Section 740.23—now authorizes the export, re-export, and transfer (in country) of certain EAR99...

General

15 May, 2024

EU Enacts New Directive Establishing Criminal Offenses for the Violation of Restrictive Measures

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. On April 24, 2024, the European Union (“EU”) officially adopted Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (the “Directive”). A copy of the...

Category: General

DXC Technology Company Settles Sanctions and Export Control Violations

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme

DOJ Antitrust Division Launches New Task Force on Health Care Monopolies and Collusion

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

Supply Chain and Sanctions Compliance (Part III of IV)

Distribution Chains and Sanctions Compliance (Part II of IV)

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

Commerce Department Promulgates New Rule Adopting Medical Device License Exception for EAR99 Exports to Russia, Belarus and Ukraine

EU Enacts New Directive Establishing Criminal Offenses for the Violation of Restrictive Measures

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