On September 30, 2025, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, announced an administrative settlement with Hallewell Ventures, Ltd. (“Hallewell”) and its beneficial owner, Russian businessman Albert Avdolyan, arising from an unauthorized reexport of a Bombardier Global 7500 aircraft to Russia in March 2022. The matter concludes with a $374,474 civil penalty, payable within thirty days of the order, and conditions...

On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List restrictions to cover affiliates of listed parties. Effective on the date of filing for public inspection, the IFR abandons the longstanding “legally distinct” standard, under which only entities expressly enumerated on the Entity...

Last week, the Justice Department announced that Cadence Design Systems Inc. (Cadence), a global electronic design automation (EDA) technology company based in San Jose, California, agreed to plead guilty to a conspiracy to violate export control laws by selling EDA hardware, software, and semiconductor design intellectual property (IP) technology to the National University of Defense Technology (NUDT). NUDT, which is a university in the People’s...

Well, we are in a new era — a fundamental change has occurred, long in the making.  National security and trade enforcement have coalesced to elevate trade risks — sanctions and export controls violations will be prosecuted aggressively by DOJ with the support and coordination with relevant regulatory agencies — OFAC, BIS, and DTCC.  My focus has not been to instill fear and knee-jerk reactions...

The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry and Security imposed significant penalties for violations. BIS Case On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor...

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies – a case that reflects the U.S. government’s intensifying focus on trade enforcement across sanctions, export controls, and customs. This...

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to prosecute the parent company that voluntarily disclosed the violations quickly after acquiring Catalyst. As detailed in court documents and in DOJ’s agreements with White Deer and Unicat, from approximately 2014 through 2021, Mani...

In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical control (“CNC”) machines, for dozens of violations of the Export Administration Regulations (“EAR”). The enforcement action stems from allegations that Haas facilitated the unauthorized export, reexport, or transfer of U.S.-origin machine...

On November 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $500,000 monetary penalty on GlobalFoundries U.S. 2 LLC and its parent, GlobalFoundries U.S. Inc., for a series of unauthorized exports to SJ Semiconductor (“SJS”), a restricted party contained on BIS’s ubiquitous Entity List. This recent enforcement action reflects BIS’s steadfast commitment to enforcing U.S. export controls, especially in...