Episode 315 - Boeing Pays $51 Million for ITAR Violations
Lawyers regularly advise clients on navigating the complex and evolving U.S. sanctions regime enforced by the Office of Foreign Assets Control (“OFAC”). When a business or individual becomes aware of a potential violation of...more
Regulators expect companies to investigate actual or potential violations completely and to disclose the nature and scope of those violations completely, in order to obtain credit for their disclosures. Identifying violations...more
On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”. The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more