Shipping goods into the United States isn’t always a seamless process. At some point, almost every U.S. importer will experience a clearance delay getting their goods through U.S. Customs & Border Protection (CBP). What does this mean? In a nutshell, a clearance delay means your shipment hasn’t cleared Customs and is still in their possession. …
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…
In November, Binance Holdings, Ltd. (“Binance”) – the largest cryptocurrency exchange in the world – paid the largest settlement in OFAC history for alleged sanctions violations. Together with other agencies, the settlement totaled over $4 billion! On top of that, the CEO also pled guilty, has relinquished his role, and must pay a personal fine…
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.” I can remember a case, years ago, when GEICO got…
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). I’m talking about Fines…
Another day. Another restriction against China. Earlier this month, President Biden signed an executive order targeting U.S. investment in certain national security technologies where that investment involves “countries of concern.” Currently, these “countries of concern” are China, Hong Kong and Macau … but mostly, China. On the same day this order was signed, the Treasury…
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…
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…