This past July, the Bureau of Industry and Security (BIS) recently issued guidance on addressing both export controls and diversion risks. (Diversion risk refers to the potential for items, technology, or services to be redirected or transferred to unauthorized end-users or end-uses, which can violate export control laws and regulations). The guidance outlines various actions BIS…
The game of deception is a bad guy’s favorite game. The lengths of trouble that these people will go to in order to violate the law is extraordinary. Whether it is firearms, drugs or even money, their skills at trying to deceive U.S. Customs or BIS is quite astounding. I have witnessed some of their…
Two Russia-born U.S. citizens, Sergey Nefedov from Anchorage, Alaska, and Mark Shumovich from Bellevue, Washington, were arrested for allegedly operating a scheme to illegally export nearly half a million dollars’ worth of snowmachines and associated parts from the United States to Russia without the required export authorization and approvals through the company Absolut Auto Sales…
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…