BIS Archives - Page 2 of 2 - Corruption, Crime & Compliance

24 Apr, 2023

Episode 271 — A Deep Dive into the Microsoft OFAC Settlement

Microsoft agreed to pay $2,980,265.86 for illegal exports of services and software to sanctioned jurisdictions and Specially Designated Nationals (“SDNs”) in violation of OFAC’s Cuba, Iran, Syria, and Ukraine-/Russia-Related sanctions programs. Most of the violations involved prohibited Russian entities or persons located in the Crimea region of Ukraine. Microsoft failed to identify and prevent the use of its products by prohibited parties. Microsoft voluntarily disclosed...

General

12 Apr, 2023

Microsoft’s OFAC Settlement Underscores Important Remedial Measures (Part II of II)

Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations. According to OFAC, Microsoft demonstrated a reckless disregard for U.S. sanctions by failing to identify that over a seven-year period, more than $12,000,000 worth of software and services were exported from the United States through Microsoft systems and servers...

General

10 Apr, 2023

Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II)

OFAC announced only one settlement in the first three months of 2023. Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable. The situation changed, however, in the first week of April 2023 – OFAC announced two enforcement actions: a major action against Microsoft and another against Uphold HQ, Inc. (“Uphold”), a U.S. money service...

Podcasts

20 Mar, 2023

Episode 266 — Joint Compliance Notice Issued on Sanctions and Export Controls Evasion

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 Departments of Commerce and Treasury issued a Joint Compliance Note (“JCN”) on the importance of compliance with the Russia Sanctions and Export Control requirement, which provides important descriptions of red flags and...

Podcasts

2 May, 2021

Episode 192 — The DOJ-SAP Settlement: A New Compliance Frontier

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program. While the Justice Department’s National Security Division (“NSD”) has settled prior export control and sanctions cases against corporations for violations of the North Korea Sanctions program, the SAP case is the first...

General

4 Feb, 2019

Export Control Reform: Major Changes for ITAR Regulations for Firearms Industry

Colleen Hurson, Of Counsel at The Volkov Law Group joins us for her first posting on the blog concerning export control reform measures applicable to the firearms industry. Colleen has substantial experience in handling export control and sanctions compliance for clients subject to the State Department’s ITAR regulations and Commerce Department’s EAR regulations. Colleen can be reached at [email protected]. This week the Trump Administration is...