When I started my career in trade compliance in 1990, our friends and foes were discussed in terms of “COCOM” – Coordinating Committee for Multilateral Export Controls. COCOM was an established group of “western bloc” member states and cooperating countries whose mission was to enact an embargo on “eastern bloc” countries (mainly Russia). During this…
As an American, born and raised in the United States of America, we tend to see our country as the world leader. However, we know that the U.S. does not dictate to every other country but works well with others. Just look at the many regimes we are a member of and actively participate in. …
Higher penalties. Suspended sentences. Admissions of fault. Public charging letters. Welcome to a new era of export enforcement. The Department of Commerce’s Bureau of Industry and Security (BIS) has changed the game when it comes to penalizing companies and individuals for export violations. How did they do it? And what does this mean for your…
Remember the postcard tax return? It’s been touted by various government officials since 1950. The idea is simple (and beautiful): What if you could file your taxes on a simple, easy-to-use postcard? Just imagine all the hours you could save! Or how about Form 1040EZ? The name itself underscores the simplicity. That is, until you…
It’s one thing to have your name in the news as part of a settlement agreement for export control violations. It’s quite another to be publicly called out by the government for apparently ignoring the new Russia sanctions. That’s exactly what happened earlier this month, when the Commerce Department issued a press release identifying dozens…
Over the past month, we’ve been inundated with calls and emails from people trying to export defense items to Ukraine. Mostly firearms, ammunition and body armor. The majority of these questions seem to come from former U.S. military personnel who are travelling to that area of the world to lend their expertise and help. It…
Tell me if this scenario raises any red flags. Your U.S. company produces complicated Industrial Microwave Systems (IMS). These systems can be used for things like food and beverage processing. With some modifications, they can also be used to create high-power directed-energy weapons systems. One day, you’re contacted by a representative from a company you’ve…
If you made a list of corporations that you’d never want to battle in court, which one would be at the top of that list? Perhaps one with $200 billion in cash? Maybe one with a market cap of $2.8 trillion and the second-most valuable brand in the world? Last month, a small Israeli company…
Eighteen years before he wrote Jurassic Park, the novelist Michael Crichton penned a different story titled The Terminal Man. It’s about a computer scientist who undergoes surgery to cure his seizures – having 40 different electrodes embedded in the amygdala part of his brain and connected to a small computer in his shoulder. Spoiler alert! …
A few weeks ago, the U.S. Department of Justice (DOJ) issued a stark warning to companies and individuals worldwide. Export and sanctions enforcement efforts are on the rise. Especially for anyone who engages with China, Russia, North Korea or Iran. During a keynote address on October 5 in New York, associate deputy attorney general John…