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- Recent Developments in Enforcement of US Export Controls and Sanctions Laws
Recent Developments in Enforcement of U.S. Export Controls and Sanctions Laws
January 13, 2017, Covington Alert
Over the past few months, the agencies responsible for criminal and civil enforcement of U.S. export control and economic sanctions laws have implemented a number of important changes in their enforcement practices. In October 2016, the U.S. Department of Justice (“DOJ”), National Security Division (“NSD”) published guidance on voluntary self-disclosures of criminal export control and sanctions violations. In June 2016, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) updated its guidance on charging and penalty determinations for civil violations of export control regulations. And effective August 2016 and January 2017, the agencies responsible for civil enforcement of export control and sanctions regulations increased the maximum civil penalties for violations of those regulations. Each of these recent updates is discussed in more detail below.
July 30, 2018, Covington Alert
On July 23, the final text of the Export Control Reform Act of 2018 (“ECRA”) was released as part of the Conference Report to accompany the National Defense Authorization Act (“NDAA”) for fiscal year 2019. The NDAA is a must-pass piece of legislation that authorizes funding for the Department of Defense, and we expect it to be enacted and signed within the next ...
April 20, 2018, Covington Alert
On April 15, 2018, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) lifted its suspension of a denial order against two companies, Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (“ZTE Kangxun,” and together with ZTE Corporation, ...
October 17, 2016, Covington Alert
Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. ...