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The U.S. Department of Commerce announced sanctions against twenty-eight Chinese governmental and commercial organizations for engaging in or enabling activities contrary to the foreign policy interests of the United States, by adding these organizations to the Entity List. The entities that were listed have been connected to human rights abuses with respect to China’s suppression of rights of the Uighurs and other predominantly Muslim ethnic minorities.

Does your Compliance Manual still define Defense Articles as “specifically designed, developed, configured, adapted, or modified for a military application”? Does it still contain two different Destination Control Statements? Regulations and government policies change. Your manual must stay current with those changes.

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.)

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 mandatory Special Assessment.