Tagged: export controls

13 Nov, 2024

The Trump Administration’s Focus on the Department of Justice and Priorities (Part III of III)

The Justice Department is about to undergo some fundamental changes. The 2nd Trump Administration will take some initial broad strokes designed to increase accountability and control of prosecutors and laws enforcement. The FBI The first on the chopping block is the FBI. Under existing law, the FBI is a component of the U.S. Department of Justice, presumably under the control and oversight of the Attorney...

General

12 Nov, 2024

Forecasting the 2nd Trump Administration: Foreign Policy Changes and Increased Trade and Tariff Enforcement (Part II of III)

The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and tools to execute the policy and promote United States businesses. Since the start of the Russia-Ukraine war and the unprecedented global sanctions and export controls regime, trade enforcement and compliance have...

General

14 Aug, 2024

Quarterly Trade Compliance Update – July 2024

Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. Click here to download the quarterly update for July. Below is a summary of events this past quarter: About the document: This handy one-pager is designed to be used by our clients to provide a quick...

General

13 Jun, 2024

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

We all know what a “core” sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have to be aware of conduct that may still violate the law but is not necessarily in the “heartland” of misconduct. DOJ, OFAC and BIS are well aware of the broad reach of...

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

14 May, 2024

DOJ and OFAC Sanctions and Export Control Detection Strategies

In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation. In a global economy, investigators from various countries have built coordination procedures by which they share intelligence and possible leads among each other. This phenomena has created a complex web of investigators who can identify relevant...

Uncategorized

22 Apr, 2024

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted commodities to U.S. adversaries, including, but not limited to, the Russian Federation and the Islamic Republic of Iran. ...

Events

4 Mar, 2024

Webinar — Export Controls Compliance: Nuts and Bolts

Webinar: Export Controls Compliance — Nuts and Bolts March 19, 2024, 12 Noon EST SIGN UP HERE The Justice Department, the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the State Department’s Directorate of Defense Trade Controls (“DDTC”) have begun an aggressive civil and criminal enforcement program. DOJ’s National Security Division has announced its intention to prosecute criminal export controls cases. From the...

General

22 Jan, 2024

2023 Sanctions Year in Review and Predictions

As always, I tend to repeat myself. However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals. DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the resources — 25 new federal prosecutors to enforce sanctions and export controls — to back up...

General

7 Dec, 2023

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

By: Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]; and Daniela Melendez, Associate at the Volkov Law Group she may be reached at [email protected] As we have repeatedly noted in the context of other blog...