Years ago, I heard an enforcement official describe deemed exports like “hugging a cloud.” As soon as you had your arms around a situation, it would dissipate – evaporating into mist, expanding, visibly there, but at the same time, somehow, not there. Fast forward to today, and the same government agency is trying to get…
What does your export compliance program look like? When was the last time you looked at it? Let’s back up further. Do you even have a compliance program? Answers to these questions are going to play a critical role for many companies this year. That’s because 2024 is shaping up to be a year of…
“Toto, I have a feeling we’re not in Kansas anymore.” Sorry, Dorothy, but we aren’t over the rainbow, either. Specifically, we’re across the ocean … in a place called Russia. Talking about a Kansas-based company named (wait for it) … KanRus Trading. Here’s what transpired in this not-so-fairytale ending. Two Americans stand accused of violating…
If you’ve spent the last year-and-a-half focused on Russia, hold that thought, and don’t take your eye off other bad actors around the world. That’s what the U.S. Government is warning with its third joint notice, published earlier this month. The previous two notices were specific to Russia. Now, the new notice warns U.S. institutions…
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…
Not surprisingly, last month’s G7 Summit solidified the persistent and unified commitment in support of Ukraine through new sanctions and export restrictions on Russia and Belarus. The purpose remains the same – the G7 countries’ continuation to cripple Russia’s ability to source goods and technology required for the war in Ukraine. This results in the…
Do you think export control laws take precedence over employment laws? Think again. Recently, two settlement agreements between the Department of Justice (DOJ) and U.S. companies highlight the complicated scenarios faced by many HR departments today. Let’s take a closer look at General Motors and American CyberSystems Inc. More importantly, let’s find out what can…
Export compliance can sometimes feel like a jigsaw puzzle that keeps adding pieces faster than you can find out where they go. In recent years, these regulations continue to change and become more complex. (Just count the pages in the Federal Register notices. They keep piling up!) Now more than ever, it’s crucial to understand…
This month, U.S. authorities imposed a $300 million civil penalty against Seagate Technology over its lucrative relationship with blacklisted Chinese technology firm Huawei Technologies. The penalty was to resolve alleged violations of export controls related to selling hard disk drives. The $300 million settlement announced by the Department of Commerce’s Bureau of Industry and Security (BIS) is…
Is it getting hot in here? Or is it just summer approaching? If you’re feeling a little “toasty,” we’re here to say that you aren’t imagining things. The agency responsible for the Export Administration Regulations (EAR) just turned up the heat on exporters. Earlier this month, the Bureau of Industry and Security (BIS) released updated…