Tag: violations

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…

Two Russia-born U.S. citizens, Sergey Nefedov from Anchorage, Alaska, and Mark Shumovich from Bellevue, Washington, were arrested for allegedly operating a scheme to illegally export nearly half a million dollars’ worth of snowmachines and associated parts from the United States to Russia without the required export authorization and approvals through the company Absolut Auto Sales…

Over the past month, we’ve been inundated with calls and emails from people trying to export defense items to Ukraine.  Mostly firearms, ammunition and body armor.  The majority of these questions seem to come from former U.S. military personnel who are travelling to that area of the world to lend their expertise and help.  It…

Tell me if this scenario raises any red flags.  Your U.S. company produces complicated Industrial Microwave Systems (IMS).  These systems can be used for things like food and beverage processing.  With some modifications, they can also be used to create high-power directed-energy weapons systems.  One day, you’re contacted by a representative from a company you’ve…

Unlicensed Exports Apply To All Foreign National Students It’s been several years since the imprisonment of John Reece Roth, a former University of Tennessee electrical engineering professor who was convicted of conspiracy, wire fraud and fifteen (15) violations of exporting ITAR controlled defense articles.  Professor Roth was involved in a U.S. Air Force contract for…

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…

Like many trade compliance professionals, I go out and peruse various trade compliance newsletters, the U.S. government agencies websites, and other media to keep up-to-date on compliance issues.  Recently, my attention was caught by a case involving Darling Industries of Tucson, Arizona. A closer look at Empowered Officials On February 28, 2019, the Directorate of…