In the ever-changing world of compliance, it is important to keep in step with new and changing requirements. BIS recently rolled out some important changes to Country Groups. Recent changes included the move of Mexico, Cyprus, and Ukraine to less restrictive country groups and the move of Hong Kong to a more restrictive group.
Effective December 14, 2020, after almost a year and half of failed discussions with the Turkish government concerning the acquisition of Russian manufactured aircraft, Section 231 of CAATSA was imposed upon the Turkish Presidency of Defense Industries (SSB).
Santa Claus may have already done his job for 2020, but the U.S. Government continues to make their lists and check them twice. For those of us in the trade compliance community, it has been difficult to keep up with all the various additions to the Restricted Parties Lists.
On December 11, 2020, DDTC published another temporary modification to help ease continued telework operations during the COVID-19 health emergency. The modification will extend remote work allowances for another six months.
There have been many changes over the last few months when it comes to China. When doing business with China, exporters and businesses must be diligent in knowing their customer, understanding what they do, who they are owned by, who they own, and what their products will be used in or with, as well as conducting robust Restricted Party Screening.
Last week, the U.S. Department of Justice announced that a former Raytheon engineer was sentenced to 38 months in prison for violations of the Arms Export Control Act (AECA).
There is an unprecedented rise of ransomware attacks against companies. As a result, many companies are finding themselves victims to cyber-attackers demanding payments to avoid shutting down their business. OFAC concerns must be addressed before any company decides to facilitate payment to cyber-attackers.
China is reviewing their current export control regulations and issuing updates, including a new law which would enable the Chinese government to take reciprocal measures against countries that undermine their export control measures and threaten their national security and interests.
The Department of Commerce added another round of entities to the Entity List that is maintained by Bureau of Industry and Security. The September 22, 2020 final rule, documented the addition of forty-seven (47) new entities spanning multiple countries.
Most companies want to do the right thing and are not intentionally violating the law, however, even companies with comprehensive import programs can make mistakes and violate the law. Once a violation has been discovered, it is important to report that violation to Customs.