Export compliance can sometimes feel like a jigsaw puzzle that keeps adding pieces faster than you can find out where they go.  In recent years, these regulations continue to change and become more complex.  Now more than ever, it’s crucial to understand these rules and regulations, why they are important, who is enforcing them, and what are the consequences.  Here are some ways the regulations are growing in complexity, and what you can do to stay ahead of the game.

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 well together.

It’s been a year since Russia launched its invasion of Ukraine.  During that time, the Treasury Department’s Office of Foreign Assets Control (OFAC) has implemented sweeping sanctions, export controls and other measures against Russia.  This includes adding more than 2,500 targets to the SDN List and sanctioning 80% of Russian banks.

Now, OFAC is targeting those who are trying to evade the sanctions. 

“We don’t export anything.” This is something we hear all the time.  Sometimes, our clients really don’t put something in a box and send it to a foreign country.  Yet, they still need help. At first, you may think to yourself: “That’s weird.  Why would a company that doesn’t export need a compliance program for exports?”  However, there are certain scenarios when even those businesses that don’t “export” in the traditional sense still need to think about export control laws and regulations.  Let’s look at a few.