Category: Violations

Is it just me, or does it seem like every day there is new activity through the Bureau of Industry and Security, Office of Export Enforcement (BIS-OEE)?  OEE seems to be everywhere, fixated with ghoulish intensity on raising a graveyard of penalties.  Let’s take a closer look at some examples and review the highlights from…

It was 6:13 p.m. The warehouse was quiet. The phones had stopped ringing. The last container had been unloaded, and everyone had gone home. Everyone… except the person in Trade Compliance. She was reviewing old entry records when she noticed something strange. One HTS classification didn’t look right. Then another. And another. She pulled the…

Halloween is the time of year for scary stories. Haunted houses, binging all the horror flicks, and exchanging ghost stories. For anyone working in trade compliance, some of the scariest stories don’t involve ghosts at all. They involve an export that left the building without the right authorization, a customer who turned out to be…

If you’ve spent any time navigating U.S. customs regulations, you’ve probably had the same thought as anyone who has assembled furniture without reading the instructions: “Surely there’s a better way.” Well, Washington appears to agree. A sweeping Executive Order on customs enforcement aims to modernize how imports enter the United States, tighten compliance, strengthen national…

Every Independence Day, communities across the country celebrate with one of America’s favorite traditions: fireworks displays. Depending on the size of the event, a professional fireworks show can cost anywhere from $5,000 for a small municipal display to well over $100,000 for large city celebrations. Major metropolitan displays can easily exceed several hundred thousand dollars….

When a Shipment Becomes a Crisis and How Export Violations Can Cripple a Company What do General Electric Company, Precision Castparts, RTX, and 3D Systems Corporation all have in common? If you said they all have a public settlement for allegations of violating ITAR regulations, you’re right! In global trade, there’s always pressure to move…

As a Sports Mom, I am familiar with IMG Academy in Bradenton Florida and was shocked to learn that it had violated the export regulations.  IMG is an elite sports academy with a state-of-the-art campus that any athlete would drool over, assuming you have over $100,000 per year for attendance. IMG has produced numerous professional…

We all know that having an EAR99 export classification is quite favorable for exporters.   Typically, it allows for No License Required (NLR) exports if other considerations and requirements such as end use and restricted party screening have been met.  However, let’s look at a common scenario that may not be on your radar outside of…

What Is the Enforce and Protect Act (EAPA)? The Enforce and Protect Act of 2015 was enacted as part of the Trade Facilitation and Trade Enforcement Act (TFTEA) and became effective in August 2016, this law gives US Customs and Border Protection (CBP) authority to investigate and stop evasion of antidumping (AD) and countervailing duties (CVD) on imported goods. Its purpose is to protect US…

Often, when we think of export compliance, our focus is on the Shipping Department and boxes going out the door.  But did you know that OFAC recently settled with a Chicago Private Equity fund for $11.48M?  This firm had been managing a $50M investment that had ties to Suleiman Kerimov, a sanctioned Russian oligarch and…