Do you remember when President Obama “lifted” the Cuba sanctions? It seems like only yesterday. There was a press release. Big headlines. Secret meetings at the Vatican. Even a photo-op with Raúl Castro (Fidel’s brother). It was all so … exciting! Predictably, within 24 hours, our email and phones started blowing up with dozens of…
A few weeks ago, the U.S. Department of Justice (DOJ) issued a stark warning to companies and individuals worldwide. Export and sanctions enforcement efforts are on the rise. Especially for anyone who engages with China, Russia, North Korea or Iran. During a keynote address on October 5 in New York, associate deputy attorney general John…
James Bond makes it look so easy. Zooming around in sports cars with an array of techno-gadgets at his fingertips, he outwits his adversaries and saves the world. He does all of this while wearing tailor-made suits and sipping martinis. After defeating every foe, he jets off to a villa in the French Riviera, where…
Two subsidiaries of Schlumberger Limited – one current and one former – were hit with sanctions violations in dual press releases this week. The combined fines totaled more than $1.5 million. According to the Treasury Department’s Office of Foreign Assets Control (OFAC), Cameron International Corporation provided oil and gas services to the Russian energy firm…
This past month we have seen multiple penalties handed down for illegal exports to prohibited destinations through the use of front companies and diversion. In three particular cases, the items were diverted to an end-user that was not originally disclosed and were shipped through an intermediary. Here is a brief overview of three recent cases…
We all remember the cute nursery rhyme “Peter Piper.” (Try reciting it five times fast!) But in today’s world of ransomware attacks, many U.S. companies are caught in a troublesome “pickle” trying to figure out what to do. Here’s the scenario. Over a weekend (particularly holiday weekends), your company may find itself hit by a…
Recently the former CEO of Stargate Apparel, Inc. and Rivstar Apparel, Inc., ran afoul of U.S. Customs and Border Protection (“CBP”) for Customs fraud due to the under-valuation of apparel imported into the United States from China. A former employee turned whistleblower filed a ‘qui tami’ whistleblower complaint under the False Claims Act. The former…
On August 9, 2021, Keysight Technologies (“Keysight”) agreed to a settlement with the Directorate of Defense Trade Controls (“DDTC”) on the allegations of committing twenty-four (24) export violations of the International Traffic in Arms Regulations (“ITAR”) for unauthorized exports of technical data and software to multiple countries that would have required licenses. Based on the…
Recently there have been an increased number of enforcement cases from the Bureau of Industry and Security (“BIS”), Office of Foreign Asset Controls (“OFAC”), and Directorate of Defense Trade Controls hitting the compliance newsletter circuit and we thought it worthwhile to outline the issues for our readership and note some key takeaways from the agency’s…
Recently, Yi-Chi Shih, of Hollywood Hills, CA was sentenced to more than five years in prison for scheming to illegally export integrated circuits with a military end-use to China. In addition, he was also ordered to pay a fine of $362,968 for restitution and $300,000 to the IRS. Aside from these convictions, Y-Chi Shih was…