Category: Violations

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…

Do you think export control laws take precedence over employment laws?  Think again. Recently, two settlement agreements between the Department of Justice (DOJ) and U.S. companies highlight the complicated scenarios faced by many HR departments today.  Let’s take a closer look at General Motors and American CyberSystems Inc. More importantly, let’s find out what can…

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…

Is it getting hot in here?  Or is it just summer approaching?  If you’re feeling a little “toasty,” we’re here to say that you aren’t imagining things.  The agency responsible for the Export Administration Regulations (EAR) just turned up the heat on exporters. Earlier this month, the Bureau of Industry and Security (BIS) released updated…

In the Chinese zodiac, 2023 is the Year of the Rabbit.  The rabbit symbolizes many different attributes, including cautiousness and self-protection.  During a recent gathering of trade compliance professionals, I heard someone mention that 2023 is “the year of export enforcement.”  I must say that I agree.  These two types of “years” seem to fit…

Earlier this month, a 72-year-old Virginia man pleaded guilty to conspiring to violate Iranian sanctions.  Behrouz Mokhtari of McLean, VA, is a naturalized U.S. citizen and a native of Tehran, Iran. According to the Justice Department, from March 2018 until approximately September 2020, Mokhtari conspired to evade Iranian sanctions administered by the Treasury Department’s Office…