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Penalties Export Controls

The Volkov Law Group

Episode 378 — Update on Export and Sanctions Enforcement Cases

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The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more

The Volkov Law Group

Episode 378 -- Update on Export Controls and Sanctions Enforcement

The Volkov Law Group on

What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more

Oberheiden P.C.

7 Keys to a Successful ITAR Compliance Program

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For companies involved in the U.S. defense industry, maintaining compliance with the federal International Traffic in Arms Regulations (ITAR) is essential. It is essential for both managing companies’ regulatory risk and...more

The Volkov Law Group

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

The Volkov Law Group on

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

The Volkov Law Group

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

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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

Baker Botts L.L.P.

Beyond the Fine: Executive Lessons in Export Compliance from the AOS Settlement

Baker Botts L.L.P. on

The Bureau of Industry and Security (BIS) recently announced a $4.25 million settlement with Alpha and Omega Semiconductor Incorporated (AOS) for 15 violations of the Export Administration Regulations (EAR). This case isn’t...more

A&O Shearman

U.S. DOJ first declination for sanctions violation since creation of M&A safe harbor

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (SDTX) announced the first-ever declination to prosecute a firm and...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

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In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Mayer Brown

UK Weekly Sanctions Update - Week of May 5, 2025

Mayer Brown on

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more

Davis Wright Tremaine LLP

Protect Yourself: U.S. Exporters Advised To Obtain End-Use and End-User Statements for All Exports, Including EAR99 Items

According to a trade press report, a Bureau of Industry and Security ("BIS"), Department of Commerce official speaking at the March 2025 BIS Update Conference on Export Controls and Policy recommended that U.S. exporters...more

Mayer Brown

UK Weekly Sanctions Update - Week of March 17, 2025

Mayer Brown on

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more

ArentFox Schiff

BIS Issues Final Rule for Voluntary Self-Disclosure Procedures

ArentFox Schiff on

On Thursday, September 12, 2024, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule updating the agency’s policies on voluntary self-disclosures and the Guidance on Charging and Penalty...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

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

Pillsbury Winthrop Shaw Pittman LLP

New UK Trade Sanctions Enforcement Body Goes Live October 10, 2024

New UK enforcement body goes live and new powers granted to existing body, regulating those doing business in the UK. UK trade sanctions enforcement risks are set to increase on October 10, 2024, as two government agencies...more

Adams & Reese

International Compliance Digest - September 2024

Adams & Reese on

New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Mayer Brown

Teeth Can Bite: Towards Harmonized Rules on EU Sanctions Criminal Enforcement

Mayer Brown on

On March 12, 2023, the European Parliament ("EP") formally endorsed the adoption of a Directive defining criminal offences and penalties for the violation of European Union ("EU") restrictive measures, colloquially known as...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

Foley & Lardner LLP on

Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Torres Trade Law, PLLC

Understanding ITAR Mandatory Disclosures and the “Duty to Inform” DDTC

Torres Trade Law, PLLC on

The discovery of actual or potential International Traffic in Arms Regulations (“ITAR”) violations presents the question of whether to disclose the conduct to the Department of State Directorate of Defense Trade Controls...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

Akerman LLP on

On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Husch Blackwell LLP

BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

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On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more

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