Episode 315 - Boeing Pays $51 Million for ITAR Violations
On July 28, the U.S. Department of Justice’s National Security Division and the Department of Commerce’s Bureau of Industry and Security (BIS) jointly announced resolutions of parallel criminal and administrative...more
On September 30, 2024, Quantum Corporation—a U.S.-based technology company— reached a settlement with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) to resolve 45 separate violations of the...more
On June 14, 2024, U.S. Department of Commerce Assistant Secretary for Export Enforcement, Matthew Axelrod, officially issued an order activating the suspended portion of a civil penalty that was imposed on U.S-based freight...more
Boeing continues to struggle with its core business activities. As troubles mount for Boeing, it is clear that it continues to suffer from real and pervasive culture issues that have been reflected in serious safety...more
Boeing continues to struggle. As troubles mount for Boeing, it is clear that it suffers from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory...more
The Commerce Department has adjusted its export control enforcement program. The Bureau of Industry and Security (“BIS”) announced the new administrative policies and gave notice to the industry and public. BIS is now...more
The path, once again, is clear: regulators look favorably upon organizations that flag compliance issues for internal investigations, self-report violations, and cooperate with government officials. This strategy was...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
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
The revised policy both clarifies and expands DOJ’s prior disclosure guidance. On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
On 3 October 2019, the Department of Energy (DOE) published a notice of proposed rulemaking regarding the imposition of civil penalties for violations of the Part 810 regulations (10 CFR Part 810), which control the export of...more
With a high-level White House meeting on Friday, the US and China have extended trade talks, even as a “final deal remains elusive” (aka, nothing at all is in writing yet). It also appears that the purported progress is...more