News & Analysis as of

Due Diligence Enforcement Actions Exports

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

American Conference Institute (ACI)

[Virtual Conference] EAR Compliance & Licensing Masterclass - July 14th - August 7th, 12:00 pm - 3:00 pm EDT

The Trump Administration is aiming to eliminate loopholes in the U.S. export controls system, expand the scope of the EAR, and ramp up enforcement. Get the insights you and your team need to strengthen your compliance program...more

Sullivan & Worcester

“What to do if things start to go wrong in a Trade, Export or Project Finance Transaction”

Sullivan & Worcester on

Jacqueline Cook, Of Counsel, sums up the key messages from Sullivan’s May webinar. Geoffrey Wynne considered what financiers could do if things start to go wrong in a trade, export or project finance transaction and...more

Holland & Knight LLP

International Trade Compliance Year in Review: 10 Enforcement Lessons from 2022

Holland & Knight LLP on

In the past year, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Department of State's Directorate of...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Global Compliance Updates - November 2nd - 3rd, 5:55 pm - 8:15 pm GST

Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Bass, Berry & Sims PLC

OFAC Settles with Cosmetics Company, Reiterates Importance of Supply Chain Compliance

• Company committed multiple apparent violations of U.S. sanctions on North Korea • Penalty imposed in part because of company’s “non-existent” sanctions compliance program • Settlement underscores need to address supply...more

King & Spalding

e.l.f. Cosmetics Agrees to Pay Nearly $1 Million To Settle Apparent Violations Of U.S. Sanctions Against North Korea

King & Spalding on

This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence - On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more

Bass, Berry & Sims PLC

U.S. Dental Supply Company Penalized for Violating Iran Sanctions

Bass, Berry & Sims PLC on

•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2017

ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

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