FCPA Compliance Report – Episode 732 – Understanding Anti-Boycott Compliance with Alexander Cotoia
ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more
As the People’s Republic of China (PRC) has emerged as a major economic power and competitor, the U.S. has leaned heavily on and enhanced its foreign direct investment regime over recent years to protect its national security...more
According to the National Center for Science and Engineering Statistics (“NCSES”), a key driver in the scientific and technological accomplishments of U.S. research universities is the volume of federal support for research...more
In recent years, the U.S. has pursued a whole-of-government approach to target Chinese technology and service providers in furtherance of foreign policy and national security objectives....more
Last week, the U.S. Government imposed tough restrictions on U.S. transactions with specific companies in the People’s Republic of China (PRC) that are involved in activities contrary to U.S. foreign policy and national...more
In his last days, President Trump takes a swipe against companies identified by the Department of Defense (DoD) as Communist Chinese military companies by prohibiting US persons from investments. On November 12, 2020,...more
On July 14, 2020, President Trump signed into law an Executive Order that ends Hong Kong’s differential treatment compared to the People’s Republic of China (“PRC” or “China”). The President’s action follows the Chinese...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more
• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia: o Effective August 26, 2019, U.S. banks (as defined below) are...more
SECOND QUARTER 2019 – - US extends sanctions to encompass Iranian metals industries and other targets; Iran announces breach of nuclear accord after EU is unable to offset economic impact of renewed US sanctions. -...more
• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more
Consistent with the ongoing United States (US) strategy of limiting engagement with China in the high-tech sector (especially telecommunications) on national security grounds, the US Department of Commerce’s Bureau of...more
On May 15, 2019, President Trump issued Executive Order 13873 entitled “Securing the Information and Communications Technology and Services Supply Chain.” The Executive Order declares a national emergency regarding...more
On May 15, 2019, President Trump issued an Executive Order (“EO”) targeting activities of certain foreign telecommunications companies based in hostile countries. Entitled “Securing the Information and Communications...more
As of May 16, 2019, Huawei Technologies Co. Ltd. of China and 68 of its non-U.S affiliates located in 26 destinations (collectively known as Huawei) were added to the Entity List maintained by the U.S. Department of Commerce,...more
On May 15, 2019, President Trump issued an Executive Order (EO), “Securing the Information and Communications Technology and Services Supply Chain.” The EO directs the U.S. Department of Commerce to lead an interagency effort...more
• On May 15, 2019, President Trump issued a long-awaited E.O. designed to curtail the use of telecommunications items and services from certain countries and persons in U.S. networks. The E.O. does not impose immediate...more
ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
The Trump Administration has been active on the sanctions front as a means of asserting U.S. foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late, beyond its...more
On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding 29 parties to its Entity List, a...more