Category: Violations

We are all familiar with the requirements of filing the Electronic Export Information (EEI) in the Automated Export System (AES); but let’s be honest- it may be a regulation, but it is more like an administrative process: you file the information and if you make a mistake, you amend it. No big thing. Maybe not…...

DDTC has announced an administrative settlement (Consent Agreement) with the company, AeroVironment, Inc. for violations of the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR) in connection with the unauthorized exports of defense articles, to include technical data, failure to properly maintain records involving ITAR-controlled transactions, and violations of the...

During all the activities (sanctions, tariffs, designated entities, etc.) of the past two months there was an updating of guidelines by Customs and Border Protection (CBP) that may have been overlooked. In July, CBP updated its Forfeiture Remission Guidelines for Export Control Violations.   Considering the fact that the last update was published in 2004, changes...

The Directorate of Defense Trade Controls (DDTC) has entered into a Consent Agreement with L3Harris Technologies, Inc. (“L3Harris”) for violations of the International Traffic in Arms Regulations (ITAR).  In its Proposed Charging Letter, DDTC alleged a total of one hundred thirty-one (131) violations.  The violations fall into the following categories: Unauthorized Exports of Technical Data...

The interim rule from the General Services Administration, the Department of Defense and NASA was published on August 7, 2019 and becomes effective today, August 13, 2019.  As a requirement of NDAA 2019, the rule prohibits federal agencies from purchasing telecommunications and video surveillance equipment, along with any “substantial or essential component of any system, or...

According to Treasury Department statistics, during the first six months of 2019, the Office of Foreign Assets Control (OFAC) has issued nearly $1.3 billion in penalties. That represents 18 settled cases and is an amount which is 17 times greater than all of 2018 (when there were seven settled cases.) The totals for OFAC penalties...

On June 20, 2019, the Department of Justice announced that Walmart and its wholly owned Brazilian subsidiary plead guilty and agreed to pay a combined criminal penalty of $137 million to resolve allegations of violations of the Foreign Corrupt Practices Act (“FCPA”). The fines include $728,898 in criminal penalties, $3,694,490 in criminal forfeiture, plus a...

So, you think your computer is fast?  The U.S., China, the European Union and Japan are in a race to build exaflop-capable supercomputers.  These machines would be capable of processing 1 quintillion - or 1,000,000,000,000,000,000 - calculations per second.  In the latest action to help the United States in this race, on June 24, 2019,...

Ever wonder why your license application is taking so long to be reviewed and approved? Many thoughts go through a Compliance Officer’s mind when the license process is taking longer than expected: “Did I make a mistake on the license application?” “Should I have provided more information?”  “Did I miss something in my due diligence?”...

Darus Zehrbach of Westover, West Virginia was recently sentenced to six months in prison for making false statements to a federal agent. Zehrbach applied for an OFAC license to export electric scooters to Iran, however, the license was denied. Despite the denial, Zehrbach exported the scooters from the United States to the United Arab Emirates....