“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…
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…
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…
In the final scene of Back to the Future, Doc Brown prepares to take his time-travelling DeLorean into the future. Marty warns Doc that they don’t have enough roadway to get the machine up to 88 mph for the time jump. And then Brown famously says: “Roads? Where we’re going we don’t need roads.” Cue…