Category: Violations

There is an unprecedented rise of ransomware attacks against companies and financial institutions who are trying to cope with the global impact of COVID-19. As a result, many companies are finding themselves victims to cyber-attackers demanding monumental payments to avoid shutting down their business operations. OFAC (Office of Foreign Asset Control) concerns that must be…

The United Arab Emirates (“UAE”) and the Kingdom of Bahrain have decided to end their involvement in the Arab League’s economic boycott of Israel.  On August 29, 2020, the president of the UAE announced the dissolving of the domestic boycott.  Domestic relations between the two countries were normalized when the Abraham Accords Peace Agreement was…

The Department of Commerce added another round of entities to the Entity List that is maintained by Bureau of Industry and Security (“BIS”). The September 22, 2020 final rule published in the Federal Register release noted here, Federal Register Notice 2020-18909, documented the addition of forty-seven (47) new entities spanning multiple countries; specifically Canada, China,…

Why are Customs Regulations Important? US Customs at its core is the top law enforcement agency for America. It was established to help control the flow of goods and people in and out of the country. One of their main obligations is to collect duties and taxes on the merchandise that is imported. They also…

In a press release earlier this month, the Bureau of Industry and Security (BIS) announced a tightening of controls against Chinese tech firm Huawei Technologies.  BIS also added an additional 38 Huawei affiliates to the Entity List – an action that will impose a license requirement for all items subject to the Export Administration Regulations (EAR)…

While we can all certainly agree that we’re not as desirable as Richard Gere tooling down the Pacific Coast Highway in his Giorgio Armani behind the wheel of a Mercedes-Benz 450 SL, I think everyone can agree that one simple phone call to your favorite compliance team might easily be the best call you’ll make…

This past week, the Trump administration announced a ban on exports of certain types of Personal Protective Equipment (PPE) in response to the COVID-19 crisis.  The new rule became effective immediately and will last four months (until August 8, 2020). While this type of activity is unusual due to its breadth and scope, those of…

On January 29,2020, Airbus SE of the Netherlands became another cog in the wheel of export enforcement. Airbus agreed to a settlement with DDTC of $10 million covering 75 violations of the Arms Export Control Act (AECA) and Part 130 of the ITAR for the time period 2011 through 2019. Outline of Violations The violations…

Updated 1/23/2020 Is Your Company’s Understanding Of ITAR Procedures Flawed? Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine): Export-controlled technical data has a unique set of rules designed to ensure that it is not inadvertently released or “exported” to…

The New Year is here and with the new year comes increased penalties for export violations pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“2015 Act”) became law in November 2015. The stated purpose of the 2015 Act is…