Episode 315 - Boeing Pays $51 Million for ITAR Violations
Season 2 Episode 4 - Russia Enforcement and the involvement of DOJ's Task Force KleptoCapture
This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more
Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more
The U.S. agencies most well-known for their enforcement of U.S. trade and national security laws are the Bureau of Industry and Security (“BIS”), the Directorate of Defense Trade Controls (“DDTC”), the Office of Foreign...more
On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more
As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more
On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more
On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more
In the United States export control laws and regulations require companies to receive export licenses prior to releasing any controlled items or technologies to non-U.S. persons. The process of determining what is controlled...more
On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more
The U.S. Department of State, Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, which regulates the brokering, export, reexport, retransfer, and temporary import of defense articles and services,...more
Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
On December 13, 2019 the Department of Justice (“DOJ”) announced a major revision of its voluntary disclosure program for criminal violations of U.S. export and sanctions laws. Under the new policy (the “Policy”), if a...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more
On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more
The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives. The National Security Division (NSD) of the US Department of Justice (DOJ)...more
U.S. companies, particularly defense and other high-tech companies, have long faced challenges of how to comply with both the deemed export rule, which may require employment discrimination in very limited circumstances, and...more
The U.S. export control system has undergone major reform in recent years, and companies have experienced both increased enforcement of export control laws and fines for violations, with more changes on the way. Skadden...more