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…
It just got more expensive to violate U.S. import/export regulations. In recent weeks, the various governmental agencies who administer and enforce these regulations have released updated penalty amounts. The main culprit? Everyone’s favorite “I” word – inflation! Here’s a rundown of the new changes. Directorate of Defense Trade Control (DDTC) DDTC is the Department of…
It may “take two to tango,” but it takes 27,000 sanctions violations to dance with the Treasury Department’s Office of Foreign Assets Control (OFAC). Last month, Tango Card, Inc. agreed to pay $116,000 to settle these violations. This case serves as an important reminder for any ecommerce business. How a gift card company got in…
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…