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…
December 1989. Dresden, East Germany. The Berlin Wall has fallen, heralding the end of the Cold War. A surge of pro-democracy sentiment sweeps through Eastern Europe. One fateful night in December, a crowd of demonstrators tries to storm a nondescript building known to be the East German headquarters of the KGB. Rushing outside, a panicked,…
Do you remember when President Obama “lifted” the Cuba sanctions? It seems like only yesterday. There was a press release. Big headlines. Secret meetings at the Vatican. Even a photo-op with Raúl Castro (Fidel’s brother). It was all so … exciting! Predictably, within 24 hours, our email and phones started blowing up with dozens of…
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…
Two subsidiaries of Schlumberger Limited – one current and one former – were hit with sanctions violations in dual press releases this week. The combined fines totaled more than $1.5 million. According to the Treasury Department’s Office of Foreign Assets Control (OFAC), Cameron International Corporation provided oil and gas services to the Russian energy firm…
We all remember the cute nursery rhyme “Peter Piper.” (Try reciting it five times fast!) But in today’s world of ransomware attacks, many U.S. companies are caught in a troublesome “pickle” trying to figure out what to do. Here’s the scenario. Over a weekend (particularly holiday weekends), your company may find itself hit by a…
SAP SE $8 million settlement Those of us with children know that some kids choose to learn “the hard way” while others take “the easy way.” The same can be said for companies trying to comply with U.S. sanctions and export control regulations. Last month, German software behemoth SAP SE (“SAP”) agreed to pay more…
As the whole world is seemingly swept-up in the “crypto craze,” the Treasury Department’s Office of Foreign Assets Control (OFAC) just issued a stark warning to those companies whose businesses involve digital currency. This comes less than a year after slapping Amazon for similar violations. In a recent press release, OFAC announced that is has…
Unlicensed Exports Apply To All Foreign National Students It’s been several years since the imprisonment of John Reece Roth, a former University of Tennessee electrical engineering professor who was convicted of conspiracy, wire fraud and fifteen (15) violations of exporting ITAR controlled defense articles. Professor Roth was involved in a U.S. Air Force contract for…