Eight miles outside of Baltimore, along a railroad line dating back to late 1800s, lies a sleepy little town of just 10,000 people. You’ll find quiet, tree-lined streets. An old stone church. And just up the road, across from Panera Bread, in a nondescript, one-story brick industrial building, a few dozen employees work in a…
The U.S. Government has certainly had a busy summer, and the current administration was serious about its commitment to increased enforcement. Months ago, they stressed that enforcement was coming, and they have indeed followed through on that promise. See the below table for recent examples. Who? Penalty What Happened? Andritz, Inc. (Pennsylvania) $1.6 million Exported…
A Noteworthy Conference with Strong Messages There has been a lot of chatter regarding the recent Bureau of Industry and Security (BIS) annual Update Conference on Export Controls and Policy, which took place recently in March. This year’s conference was particularly noteworthy as it marked the first time Commerce Secretary Howard Lutnick addressed export controls…
By now, we have all seen the updates to the Boycott Requester List from the Department of Commerce’s Bureau of Industry and Security (BIS), with the most recent update on April 3, 2025. This blog aims to address the fundamental question: What exactly is this list, and more critically, what are the implications if an…
Regulatory Blast – Drinking from a Firehose! The recent regulatory landscape is ever changing. In fact, I am finding it hard to stay up to date – and I am what some may say “experienced”! The other day, I told a colleague that I had not had an easy question to answer that week! In…
This past July, the Bureau of Industry and Security (BIS) recently issued guidance on addressing both export controls and diversion risks. (Diversion risk refers to the potential for items, technology, or services to be redirected or transferred to unauthorized end-users or end-uses, which can violate export control laws and regulations). The guidance outlines various actions BIS…
The game of deception is a bad guy’s favorite game. The lengths of trouble that these people will go to in order to violate the law is extraordinary. Whether it is firearms, drugs or even money, their skills at trying to deceive U.S. Customs or BIS is quite astounding. I have witnessed some of their…
Years ago, I heard an enforcement official describe deemed exports like “hugging a cloud.” As soon as you had your arms around a situation, it would dissipate – evaporating into mist, expanding, visibly there, but at the same time, somehow, not there. Fast forward to today, and the same government agency is trying to get…
When I started my career in trade compliance in 1990, our friends and foes were discussed in terms of “COCOM” – Coordinating Committee for Multilateral Export Controls. COCOM was an established group of “western bloc” member states and cooperating countries whose mission was to enact an embargo on “eastern bloc” countries (mainly Russia). During this…
It’s one thing to have your name in the news as part of a settlement agreement for export control violations. It’s quite another to be publicly called out by the government for apparently ignoring the new Russia sanctions. That’s exactly what happened earlier this month, when the Commerce Department issued a press release identifying dozens…