On July 26th, U.S. government agencies published a “tri-seal note” describing the Voluntary Self-Disclosure (VSD) policies applicable to export controls. This is the second joint document issued by three key U.S. regulators – the Department of Commerce, Bureau of Industry and Security (BIS), the Department of the Treasury, Office of Foreign Assets Control (OFAC), and…
Who’s Responsible For Trade Compliance? This is a question that most companies struggle with when it comes to their imports or exports. Who is responsible? The answer… everyone! Some companies might have a designated Trade Compliance Manager who oversees the trade compliance program. Others might even have a dedicated team built just for compliance. Other…
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.) The totals for OFAC penalties…
After a delay due to the government shutdown, the U.S. government recently announced increases to civil penalties for export related violations. Pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, civil penalties for export related violations should have increased on 3 January 2019. However, given the fact that the USG was…