Stop me if you’ve heard this one:  “We don’t make munitions or sell weapons, so we are good on all those export-law requirements.” Statements like this make most trade compliance managers cringe.  Why?  Because there’s so much more to import/export compliance than just “selling munitions.”  Take the enforcement case announced last month against 3M Company. 

Trade compliance audits can be scary, cumbersome and time-consuming.  Why would any company subject itself to this?  The importance of any import/export compliance audit is to avoid the dreaded “F&P” words.  These are two words that most companies don’t want to hear … or even say (unless it’s behind closed doors). Maybe this has never crossed your mind.  If it has, keep reading and we’ll help you unpack the details.

Deemed export laws are complicated.  They can be confusing for all people – even Elon Musk.  The serial entrepreneur and founder of SpaceX recently tweeted an (inaccurate) interpretation of U.S. export controls laws.  Let’s expand beyond 280 characters and take a closer look at this topic.

Whether you're a business owner, financial professional, or anyone transacting globally, understanding the Office of Foreign Assets Control (OFAC) is crucial. OFAC plays a vital role in enforcing economic and trade sanctions against targeted individuals, organizations, and countries.

In the 2008 comedy Burn After Reading, Brad Pitt and Francis McDormand play two clueless gym employees who try (and fail) to make money selling government secrets.  And while bribery, espionage and money laundering sound like all the good plot points for any spy comedy, you don’t expect to find them in the real world – with real government employees trying to sell real secrets.

On July 26th, U.S. government agencies published a “tri-seal note” describing the Voluntary Self-Disclosure (VSD) policies applicable to export controls.  This is the second joint document issued by three key U.S. regulators – the Department of Commerce, Bureau of Industry and Security (BIS), the Department of the Treasury, Office of Foreign Assets Control (OFAC), and the Department of Justice (DOJ).