Treasury: Largest Settlement in History

In combination with OFAC, FinCEN, and IRS, Treasury is announcing the largest settlement in history. This is with Binance Holdings for violations of anti-money laundering and sanctions laws. Binance is a virtual currency exchange, responsible for ~ 60% of virtual…

Justice: Virginia Tactical Gear Company Settles False Claims Act Allegations

A tactical gear and equipment company from Virginia is paying ~$2.1million to for False Claim Act allegations – they were selling textile-based products to the Department of Defense, and claimed that they complied with Buy American Act, the Trade Agreements…

2 people looking at a textbook

Export Screening

Do you know who you’re doing business with? One of the key elements to due diligence in export transactions is knowing your customer. We will dig into the regulations and guidance from government agencies, and walk you through steps that…

DSCA: The Defense Counterintelligence and Security Agency Report Exposes Foreign Intelligence Targets

The Defense Counterintelligence and Security Agency put out a report of sectors that are being targeted. This is on areas that foreign intelligence is targeting. When they refer to “cleared industry”, my military source tells me that means those that…

Commerce: Temporary Halt on Firearms, Components, and Ammo Licensing for 90 Days

As of 10/27/2023 Commerce is pausing issuing licenses for firearms, components, and ammo for ~ 90 days. During this “pause” period, the Department will further assess current firearm export control review policies to determine whether any changes are warranted to…

BIS: Bureau of Industry and Security Published Interim Final Rule

Interim Final Rule (IFR) on the Implementation of Additional Export Controls: Certain Advanced Computing and Semiconductor Manufacturing Items; Supercomputer and Semiconductor End Use. Effective 11/17/2023, discussion of comments. Read More

EPA: The Environmental Protection Agency Published Rule on Hydrofluorocarbons

A rule on hydrofluorocarbons (HFCs) was published 10/24. It’s effective 12/26. HFCs are a group of synthetic gases that are used mostly for cooling and refrigeration. As part of the American Innovation and Manufacturing Act, the EPA can limit the…

CTPAT Supply Chain Security

Why, How, and How Much:  CTPAT is the new normal and an industry standard. Changes to the minimum-security criteria (MSC) in 2020, remote validations, and recent developments are requiring new and existing CTPAT program members to dedicate increased attention and…

Justice: A Florida Couple Plead Guilty to Duty Evasion

A couple from Florida plead guilty to duty evasion on plywood imports, and selling illegally imported plywood products, as well as smuggling and violations of the Lacey Act. The loss of duties was ~ $42 million. Read More

CBP: Joint Forces Uncover Who Stole Dinosaur Bone

U.S. Customs and Border Protection worked with Bureau of Land Management to find people who stole dinosaur bones from Utah to sell and export. The defendants were in court in October. Read More

BIS: Issued an Update for Samsung and SK hynix

The Bureau of Industry and Security issued a rule updating the general authorizations for Samsung and SK hynix for semiconductor facilities in PRC. This is under the Validated End-User (VEU) program. This basically gives the South Korea companies permission to…

Justice: New Safe Harbor Policy

The Deputy AG announced new Safe Harbor policy for VSDs that are made in connection with mergers and acquisitions. This was during the remarks that Lisa Monaco gave at the Society of Corporate Compliance and Ethics’ 22nd Annual Compliance and…