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
Pursuant to a sweeping new executive order (EO) issued on June 30, 2025, the Trump administration has lifted virtually all U.S. sanctions targeting Syria, shuttered the Syria sanctions program administered by the Office of...more
President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...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 November 2, 2020, the White House released a notice continuing the national emergency with respect to Sudan declared in Executive Order 13067 of 1997. Secretary of State Mike Pompeo issued a press statement clarifying...more
Hong Kong Updates and Alerts - New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended - On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...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
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
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
Effective October 12, the Trump administration revoked the U.S. embargo on Sudan in accordance with Executive Order 13761 (Jan. 13, 2017) and Executive Order 13804 (July 11, 2017). As a result of this action, Sudan and the...more
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
On October 6, 2017, President Donald Trump and the U.S. Department of State announced the revocation of economic sanctions on Sudan, following the temporary lifting of sanctions on January 17, 2017. The announcement concluded...more
On July 11, 2017, President Trump issued an executive order that postpones any decision regarding whether to terminate the comprehensive sanctions regime against Sudan for an additional three months—until October 12, 2017....more