The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more
7/23/2025
/ Broker-Dealer ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Regulatory Requirements ,
Sanctions ,
Self-Disclosure Requirements
On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a...more
7/15/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Failure To Disclose ,
Huawei ,
International Trade ,
Penalties ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department ,
Unauthorized Transactions
On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and...more
In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical...more
2/5/2025
/ Blocked Person ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Russia ,
Sanction Violations ,
SDN List ,
US Trade Policies
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations...more
1/10/2025
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
Sanction Violations ,
U.S. Commerce Department
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more
12/4/2024
/ Compliance ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Health Insurance ,
Iran ,
Iran Sanctions ,
ITSR ,
Life Insurance ,
MetLife ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Politically Exposed Person (PEPs) ,
Sanction Violations ,
U.S. Treasury ,
United Arab Emirates (UAE) ,
White Collar Crimes
In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property...more
10/11/2024
/ Civil Monetary Penalty ,
Compliance ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Office of Financial Sanctions Implementation (OFSI) ,
Property Management Companies ,
Russia ,
Sanction Violations ,
UK ,
Ukraine
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
9/12/2024
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Subsidiaries ,
Internal Controls ,
John Deere ,
Securities and Exchange Commission (SEC) ,
Statutory Violations ,
White Collar Crimes
On August 15, 2024, the U.S. Department of Commerce’s Office of Export Enforcement (“OEE”) announced the settlement of the latest administrative enforcement action involving TE Connectivity Corporation—a Pennsylvania-based...more
On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations...more
Organizations with operations in California are reminded of the upcoming July 1, 2024 deadline to comply with the provisions of S.B. 553—a bill that was signed into law by Governor Gavin Newsom on September 20, 2023,...more
6/25/2024
/ Cal-OSHA ,
California ,
Compliance ,
Deadlines ,
Employee Training ,
Employer Liability Issues ,
Labor Code ,
Labor Reform ,
New Legislation ,
Policies and Procedures ,
State Labor Laws ,
Workplace Safety ,
Workplace Violence ,
Workplace Violence Prevention Programs
On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more
6/19/2024
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Compliance ,
Corruption ,
Cross-Border Transactions ,
EU ,
EU Directive ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Money Laundering ,
New Rules ,
Terrorism Funding ,
Terrorist Financing Regulations ,
White Collar Crimes
On June 3, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the resolution of an administrative enforcement action brought against Airbus DS Government Solutions (“Airbus DSGS”)—a...more
6/12/2024
/ Airbus ,
Antiboycott Requirements ,
Boycotts ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Defense Sector ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Popular ,
Statutory Violations ,
U.S. Commerce Department
On April 24, 2024, the European Union (“EU”) officially adopted Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU)...more
On March 28, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released updated guidance to freight forwarders specifically outlining their responsibilities under the aegis of the Export...more
On April 15, 2023 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals...more
Challenges may arise when conducting an internal investigation related to an underlying disclosure by a whistleblower pursuant to the EU Directive, because companies must strictly comply with the GDPR. Failure to comply with...more
3/29/2024
/ Compliance ,
Consent ,
Corporate Misconduct ,
Data Management ,
Data Processing Rules ,
Data Protection ,
Data Protection Impact Assessments (DPIAs) ,
Employer Liability Issues ,
EU ,
General Data Protection Regulation (GDPR) ,
Internal Investigations ,
Internal Reporting ,
Whistleblowers
The sheer proliferation of supply chain transparency and accountability regulations at international scale itself warrants a closer look at the level of scrutiny required of organizations with complex, multi-faceted, global,...more
3/7/2024
/ Audits ,
Compliance ,
Due Diligence ,
Exploitation ,
Export Controls ,
Forced Labor ,
Human Rights ,
Regulatory Oversight ,
Risk Management ,
Suppliers ,
Supply Chain ,
Sustainability ,
Third-Party Service Provider ,
Transparency
News recently published by multiple media outlets suggest that certain subcomponents incorporated into a variety of Volkswagen-owned vehicles—including cars manufactured by luxe brands Porsche, Bentley and Audi—were sourced...more
2/20/2024
/ Automotive Industry ,
China ,
Compliance ,
Customs and Border Protection ,
Forced Labor ,
Goods or Services ,
Human Rights ,
Importers ,
Imports ,
Popular ,
Supply Chain ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Volkswagen
On February 1, 2024, President Joseph R. Biden, Jr. promulgated Executive Order 14115 (“E.O. 14115), the effect of which is to impose economic sanctions on individuals ostensibly contributing to gratuitous violence and...more
Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more
2/8/2024
/ Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corruption ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Regulatory Violations ,
US Trade Policies
On January 16, 2024, the U.S Department of Commerce’s Bureau of Industry and Security (“BIS”) released a series of enhancements to its existing voluntary self disclosure (“VSD”) program, pursuant to which organizations...more
On December 31, 2021, President Joseph R. Biden, Jr. signed the the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the...more
1/25/2024
/ China ,
Compliance ,
Corruption ,
Customs and Border Protection ,
Entity List ,
Exploitation ,
Forced Labor ,
Foreign Policy ,
Human Rights ,
Popular ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
As global political tensions continued to escalate on multiple fronts, the 2023 calendar year saw a noticeable increase in the number of enforcement actions initiated by the U.S. government against entities and individuals...more
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
1/9/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
NDAA ,
Proposed Regulation ,
Regulatory Agenda ,
White Collar Crimes