You are reading the January 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.
To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any actions addressed in the Roundup, please contact the international trade team. We welcome your feedback and encourage you to share this newsletter. Let's jump in!
Overview
- January saw continuing focus on Russia. First, the Commerce Department's Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for illegally exporting thousands of U.S. microelectronics to Russia. Third, the Treasury Department's Office of Foreign Assets Control (OFAC) designated a United Arab Emirates (UAE) shipping company for violating the oil price cap.
- There were two notable actions involving Iran this month. The Department of Justice (DOJ) charged four Chinese nationals with illegally procuring U.S.-origin products for Iranian efforts to produce unmanned aerial vehicles (UAVs) and ballistic missiles. Also, a U.S. citizen was sentenced to two years in prison for improperly exporting heavy machinery to Iran using the UAE as a transshipment point.
- BIS imposed a $153,175 penalty against Wabtec Corporation for violations of the antiboycott regulations—an unusually large penalty in the context of boycott enforcement.
- SAP SE, a global software company, entered into a Deferred Prosecution Agreement (DPA) with the DOJ and resolved a Securities and Exchange Commission (SEC) investigation into bribery schemes involving a number of countries in Africa, Indonesia, and elsewhere in violation of the Foreign Corrupt Practices Act (FCPA).
- Lastly, a new BIS policy announced several "key updates" to BIS's Voluntary Self-Disclosure (VSD) process and hinted at increased penalties for export control violations going forward.
Click here to read the full newsletter.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.