Tagged: trade compliance

20 Feb, 2024

UFLPA in Focus: Lessons to Be Learned from Volkswagen’s Recent Experience

News recently published by multiple media outlets suggest that certain subcomponents incorporated into a variety of Volkswagen-owned vehicles—including cars manufactured by luxe brands Porsche, Bentley and Audi—were sourced from an unspecified region in “western China” (“PRC”) presumed to be the Xinjiang Uyghur Autonomous Region (“XUAR”). According to these sources, Volkswagen itself was not aware of the origin of the part, which, according to the Financial...

General

1 Feb, 2024

Quarterly Trade Compliance Update – January 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 January. Below is a summary of events this past quarter: Venezuela – Russia – Middle East – General – About the document: This handy one-pager is designed to...

Events

21 Sep, 2023

Webinar: Elevating Your Sanctions and Export Controls Compliance Program

October 24, 2023 12 Noon EST Sign up HERE The Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. DOJ’s message has been reinforced by the Departments of Treasury (Office of Foreign Asset Control, or “OFAC”) as to sanctions, and the Department of Commerce (Bureau of Industry and Security, or “BIS”), as to export controls....

Podcasts

12 Sep, 2021

Episode 206 — Update on Sanctions Compliance and Enforcement

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) continues to bring sanctions enforcement actions. At the same time, OFAC is reiterating the importance of sanctions compliance program. Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word — setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations. In this Episode, Michael Volkov...

General

7 Sep, 2021

Trade Compliance Dominates Enforcement Landscape (Part I of IV)

Well, we are still waiting for the “big” FCPA enforcement actions. Do not get me wrong – they are coming. My suspicion is that they are being held up and calculated with a splash to announce the results of the White House’s Global Anti-Corruption Memorandum focusing on the anti-corruption effort as a national security priority. The landscape is ready for a splash and DOJ is...

General

3 Aug, 2021

Unraveling Trade Compliance Issues Involving China’s Human Rights Abuses in Xinjiang

Companies with supply chains stretching into China and Xinjiang are facing a mountain of compliance challenges. Over the summer, the Biden Administration has taken numerous aggressive steps to pressure China to address human rights violations in the Chinese province of Xinjiang focusing on the repression of more than a million Uyghurs in that region. Those companies that maintain supply chains anywhere in Xinjiang have to...

Podcasts

14 Mar, 2021

Episode 185 – Anti-Boycott Compliance: Interview of Alex Cotoia from the Volkov Law Group

Mike Volkov interviews Alex Cotoia, Regulatory Manager and Compliance Consultant at the Volkov Law Group, concerning trade compliance and anti-boycott issues. Alex specializes in corporate risk assessments, evaluation of general compliance programs, and the remediation of compliance deficiencies. He also specializes in trade (export) compliance and is familiar with a broad range of issues arising under both the Arms Export Control Act and its implementing...

Podcasts

17 Feb, 2019

Episode 77 — Implementing an Effective Trade Compliance Program

Companies involved in export and import activities face a variety of risks from sanctions and export controls created by a complex maze of regulations and oversight from the Department of State, Department of Treasury and the Department of Commerce. With the increasing complexity of sanctions regimes, companies have to devote significant attention and resources to implement an effective trade compliance program. In this episode, Michael...

General

22 Jan, 2019

Merging Trade Compliance and Ethics and Compliance Silos

Business operations can be riddled with inefficiencies. It is easy to spot them inside a company. The same rule applies to ethics and compliance programs. Given a specific global business configuration, ethics and compliance programs have to be designed efficiently to support the business. For some reason, a number of compliance programs have been built with two separate silos – one for trade compliance and...

General

3 May, 2018

FLIR Systems ITAR Settlement Outlines Important Export Compliance Factors (Part II of II)

The FLIR Systems settlement is an extraordinary event given the sheer number of violations, the systemic breakdown that occurred, and the absence of any meaningful compliance controls. It is all the more surprising given the fact that FLIR’s operations are devoted in large proportion to the highly-regulated international defense industry market. Given the level of risk, you would expect FLIR to have in place systems...