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…

Buy American/America/TAA

Three programs – what do they mean?  The Trade Agreements Act, Buy American Act, and Buy America Act are three unique opportunities that may be available to your business to increase sales and improve your likelihood of getting that contract.…

DDTC: Directorate of Defense Trade Controls issued an ITAR Compliance Risk Matrix

The Department of State, Directorate of Defense Trade Controls (DDTC) is issuing a new ITAR Compliance Risk Matrix, accompanied by a supplemental risk matrix specific to universities. These risk matrices are intended to assist organizations in assessing their level of…

BIS: Bureau of Industry and Security Published Guidance on Best Practice

BIS published guidance on Best Practice: Certification to Prevent Diversion to Russia of Highest Priority Items. They identified 45 HS codes that have controlled items that are at risk of being diverted due to their importance to Russia’s ware efforts.…

Sanctions in Singapore

Singapore is fining Hydronav Services, a Singpore company, for violations of their export controls in sending goods to Myanmar. They lied and said it was going to Indonesia. Read More

CBP: Customs and Border Protection Releases August 2023 Monthly Update

August 2023 statistics are here. Details on migration, narcotics traffic, travel, the CBP One app, forced labor and intellectual property, and agriculture topics. Read More

OFAC: The Office of Foreign Assets Control Settled with 3M and Emigrant Bank

OFAC settled with 3M and Emigrant Bank for $9,618,477. This is for a potential civil liability for 54 apparent violations of sanctions on Iran. 3M’s subsidiary sold reflective license plate sheeting to an Iranian entity controlled by Iranian law enforcement.…

USTR: Section 301 Exclusions Extended Expiration Date

The existing Section 301 Exclusions that were set to expire 9/30/2023 are now extended until 12/31/2023. The list of impacted HS codes and items are in the Federal Register notice. Read More

Mergers & Acquisitions

Ignorance is NOT bliss:  Ignorance IS NOT bliss A major concern for companies in mergers and acquisitions is successor liability. Successor liability occurs when a company is acquired and subsequently inherits the burdens and liabilities of the previous organization. This…

CBSA: Updates to CARM Release 2 Timeline

In May 2024, CARM will become the official system of record for the collection of duties and taxes for commercial goods imported into Canada. Release 2 soft launch is planned for October 2023 to allow selected industry partners to test…

GAO: The Government Accountability Office issued report on the Export-Import Bank

The Government Accountability Office issued their report on the Export-Import Bank monitoring of dual-use items that they finance. The bank did not finance any new dual-use exports in FY 2022. It continued to monitor use of two satellites sold to…

BIS: Bureau of Industry and Security Amended the EAR

Bureau of Industry and Security amended the EAR to create another way to renew Temporary Denial Orders (TDOs). The new option allows BIS to request that the Export Enforcement Assistant Secretary renew an existing TDO for a year, instead of…