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.

When it comes to bringing product into the United States from a foreign country, there are a lot of customs brokers and courier services that will get this done for you.  But beware, they don’t always do it the correctly and you, as the importer, are responsible regardless of who you have hired to assist.

After the Wassenaar Arrangement (WA) Plenary meeting in December 2021, BIS announced four technologies that meet the criteria of Section 1758 of the Export Control Reform Act which is specific to emerging and foundational technologies.

Much like the Open General Export Licenses (OGELs) popular in the United Kingdom, these two general licenses will give exporters authorization to reexport and retransfer unclassified defense articles to pre-approved parties in Australia, Canada, and the United Kingdom. This means that if your transaction meets the criteria for the OGL, you will not need to submit a license for the reexport or retransfer.

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 organization going forward?

Rest assured that the U.S. government and our allies are focused on enforcing the sanctions and restrictions on Russia as a result of Russia’s invasion of Ukraine. In recent remarks, the Assistant Secretary for Export Enforcement, described the Department of Commerce’s actions in preventing Russia from obtaining tools of war.

Often in the course of daily business, it is easy to forget that there is a lot to maintain when it comes to ITAR compliance. Consider a spring clean-up focused on organizing and bringing your program back to life. Here are three things you should do this spring to ensure your ITAR program is in top shape.

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 face a six-figure penalty … not to mention a wave of bad publicity.