Category: Violations

Higher penalties. Suspended sentences. Admissions of fault. Public charging letters. Welcome to a new era of export enforcement. The Department of Commerce’s Bureau of Industry and Security (BIS) has changed the game when it comes to penalizing companies and individuals for export violations. How did they do it? And what does this mean for your…

On December 23, 2021, President Biden signed the Uyghur Forced Labor Prevention Act (UFLPA) into law.  This establishes a new rebuttable presumption that any goods, wares, articles, or merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) of China is produced by forced labor. This presumption prohibits the…

Are you shopping for explosives to use in your next gold mining operation?  (Well, of course you are!  Isn’t everyone?)  Here’s some free professional advice:  Don’t purchase these explosives from Cuba.  Specifically, from a state-owned entity that is subject to the Office of Foreign Assets Control’s (OFAC) Cuban Assets Control Regulations (CACR).  Otherwise, you could…

It’s one thing to have your name in the news as part of a settlement agreement for export control violations.  It’s quite another to be publicly called out by the government for apparently ignoring the new Russia sanctions.  That’s exactly what happened earlier this month, when the Commerce Department issued a press release identifying dozens…

Over the past month, we’ve been inundated with calls and emails from people trying to export defense items to Ukraine.  Mostly firearms, ammunition and body armor.  The majority of these questions seem to come from former U.S. military personnel who are travelling to that area of the world to lend their expertise and help.  It…

Tell me if this scenario raises any red flags.  Your U.S. company produces complicated Industrial Microwave Systems (IMS).  These systems can be used for things like food and beverage processing.  With some modifications, they can also be used to create high-power directed-energy weapons systems.  One day, you’re contacted by a representative from a company you’ve…

Do you remember when President Obama “lifted” the Cuba sanctions?  It seems like only yesterday.  There was a press release.  Big headlines.  Secret meetings at the Vatican.  Even a photo-op with Raúl Castro (Fidel’s brother).  It was all so … exciting! Predictably, within 24 hours, our email and phones started blowing up with dozens of…

A few weeks ago, the U.S. Department of Justice (DOJ) issued a stark warning to companies and individuals worldwide.  Export and sanctions enforcement efforts are on the rise.  Especially for anyone who engages with China, Russia, North Korea or Iran. During a keynote address on October 5 in New York, associate deputy attorney general John…

James Bond makes it look so easy.  Zooming around in sports cars with an array of techno-gadgets at his fingertips, he outwits his adversaries and saves the world.  He does all of this while wearing tailor-made suits and sipping martinis.  After defeating every foe, he jets off to a villa in the French Riviera, where…

Two subsidiaries of Schlumberger Limited – one current and one former – were hit with sanctions violations in dual press releases this week.  The combined fines totaled more than $1.5 million. According to the Treasury Department’s Office of Foreign Assets Control (OFAC), Cameron International Corporation provided oil and gas services to the Russian energy firm…