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Criminals are not as smart as they think they are. There is nothing so unique that elevates a scheme into the ethereal world of brilliance. The schemes get to be “typical” and the means by which they are executed are often...more
The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws. Companies have to weigh carefully the risks when...more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club. BIS’s recent announcement of new policies to administrative actions should not be surprising. ...more
Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more