Regulatory Blast – Drinking from a Firehose! The recent regulatory landscape is ever changing. In fact, I am finding it hard to stay up to date – and I am what some may say “experienced”! The other day, I told a colleague that I had not had an easy question to answer that week! In…
Two Russia-born U.S. citizens, Sergey Nefedov from Anchorage, Alaska, and Mark Shumovich from Bellevue, Washington, were arrested for allegedly operating a scheme to illegally export nearly half a million dollars’ worth of snowmachines and associated parts from the United States to Russia without the required export authorization and approvals through the company Absolut Auto Sales…
Export compliance can sometimes feel like a jigsaw puzzle that keeps adding pieces faster than you can find out where they go. In recent years, these regulations continue to change and become more complex. (Just count the pages in the Federal Register notices. They keep piling up!) Now more than ever, it’s crucial to understand…
It’s been a year since Russia launched its invasion of Ukraine. During that time, the Treasury Department’s Office of Foreign Assets Control (OFAC) has implemented sweeping sanctions, export controls and other measures against Russia. This includes adding more than 2,500 targets to the SDN List and sanctioning 80% of Russian banks. Now, OFAC is targeting…
Are you shopping for explosives to use in your next gold mining operation? (Well, of course you are! Isn’t everyone?) Here’s some free professional advice: Don’t purchase these explosives from Cuba. Specifically, from a state-owned entity that is subject to the Office of Foreign Assets Control’s (OFAC) Cuban Assets Control Regulations (CACR). Otherwise, you could…
Tell me if this scenario raises any red flags. Your U.S. company produces complicated Industrial Microwave Systems (IMS). These systems can be used for things like food and beverage processing. With some modifications, they can also be used to create high-power directed-energy weapons systems. One day, you’re contacted by a representative from a company you’ve…
December 1989. Dresden, East Germany. The Berlin Wall has fallen, heralding the end of the Cold War. A surge of pro-democracy sentiment sweeps through Eastern Europe. One fateful night in December, a crowd of demonstrators tries to storm a nondescript building known to be the East German headquarters of the KGB. Rushing outside, a panicked,…
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…
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…
According to Treasury Department statistics, during the first six months of 2019, the Office of Foreign Assets Control (OFAC) has issued nearly $1.3 billion in penalties. That represents 18 settled cases and is an amount which is 17 times greater than all of 2018 (when there were seven settled cases.) The totals for OFAC penalties…