Category: Violations

Adding to a list of seemingly never-ending problems, the Boeing Company recently agreed to pay a $51 million civil penalty for violating U.S. export regulations, specifically the International Traffic in Arms Regulations (ITAR) and Arms Export Control Act (AECA).  The company also agreed to remedial compliance measures and entered into a Consent Agreement with the…

The Foreign Trade Division of the U.S. Census Bureau is the official source for U.S. export and import statistics.  This agency is responsible for issuing regulations governing the reporting of all export shipments from the United States.  Any exporter who ships outside of the United States is responsible for complying with these regulations and for…

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…

Deemed export laws are complicated.  They can be confusing for all people – even Elon Musk.  The serial entrepreneur and founder of SpaceX recently tweeted an (inaccurate) interpretation of U.S. export controls laws.  This stems from the Department of Justice suing SpaceX for alleged discriminatory hiring practices. Musk tweeted: US law requires at least a…

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…