One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance professionals are nimble. It comes with the territory.  Building and maintaining a compliance program, requires compliance professionals to adjust their focus and prioritize resources and time...

Last year, the Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. Deputy Attorney General Lisa Monaco stated that sanctions and export enforcement constituted “The New FCPA.” DOJ, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) have joined forces to aggressively enforce sanctions...

Webinar: “The New FCPA”: Sanctions and Export Control Enforcement Tuesday, June 6, 2023, 12 Noon EST Sign Up HERE Last year, the Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. Deputy Attorney General Lisa Monaco stated that sanctions and export enforcement constituted “The New FCPA.” DOJ, the Treasury Department’s Office of Foreign Asset Control...

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...

This week’s show discusses recent developments in the sphere of export controls and sanctions. Alexander Cotoia, Regulatory Compliance Manager at the Volkov Law Group, joins Michael Volkov to explore the the Department of Commerce’s Bureau of Industry and Security (“BIS”) ramping up of export control enforcement, including the new restrictions on China and Russia. In early October, the BIS announced two rules imposing significant export...

The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement, promised to ramp up enforcement during his confirmation hearings. The Biden Administration has promised an increase in regulatory enforcement, and there is no question that enforcement...

The D.C Circuit Court of Appeals sits in a unique position as the primary reviewing court for federal government agency actions.  As a result, the D.C. Circuit sits in a high-profile position and several judges have eventually ended up at the Supreme Court. Given the rising importance and enforcement of export sanctions and controls, the D.C. Circuit Court is addressing important issues on appeal relating...