Photo of Mi-Yong Kim

Mi-Yong Kim

Mi-Yong Kim has nearly 25 years of experience related to export controls and national security. Based on her extensive government service, she is uniquely well equipped to provide advice to help clients navigate the complex regulations related to export controls and national security, including matters related to compliance with the Export Administration Regulations (EAR); the International Traffic in Arms Regulations (ITAR); the Committee on Foreign Investment in the United States (CFIUS); and foreign ownership, control, or influence (FOCI) mitigation by the Defense Security Service. Mi-Yong is also an Adjunct Professor at the National Chengchi University (NCCU) in Taipei, Taiwan. She teaches a graduate-level class on export controls and related topics at the College of International Affairs of NCCU.

You are reading Bass, Berry & Sims’ February 2023 edition of our Monthly Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.

February saw several interesting enforcement actions. From a Chinese “spy balloon’s” cross-country journey to the first anniversary of the war in Ukraine, the news of the day seemed to drive much of the enforcement activity. Let’s get into it!

Continue Reading International Trade Enforcement Roundup – February 2023

You are reading Bass, Berry & Sims’ enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.

January saw a bevy of interesting enforcement actions and regulatory policy changes. A high-level former FBI agent was charged with sanctions violations, for the first time ever a North Korean national was extradited to the U.S. for money laundering to benefit designated persons, and yet another instance of Chinese espionage was thwarted. Let’s jump in!

Continue Reading International Trade Enforcement Roundup – January 2023

You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.

December was a busy month! A highly complex Russian procurement network dismembered, a former Marine indicted, a government contractor sentenced to prison for export violations, and temporary denial orders (TDOs) galore! Let’s get into it.

Continue Reading International Trade Enforcement Roundup – December 2022

The Bass, Berry & Sims international trade team continues to monitor U.S. government action in response to Russia’s invasion of Ukraine. In the final months of 2022, the U.S. government added multiple individuals and entities to the Specially Designated Nationals (SDN) List and the Entity List (EL), froze assets of individuals, issued or revised general licenses, and took enforcement action against individuals and companies. This post summarizes new U.S. sanctions and export restrictions as of Friday, December 30. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Department of the Treasury and Department of State Designations

On December 22, the Department of the Treasury, Office of Foreign Assets Control (OFAC), in consultation with the Department of State, added 10 entities associated with the Russian Navy and/or the Russian maritime industry to the SDN List.

Continue Reading Russia, Ukraine: Update as of Friday, December 30

You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.

Following an active October, enforcement actions and regulatory policy changes slowed in November. With that said, the actions taken in November involved some novel topics and provide several insights to glean.

Continue Reading International Trade Enforcement Roundup – November 2022

You are reading Bass, Berry & Sims’ new enforcement roundup, where we bring notable enforcement actions, policy changes, interesting news articles and a bit of our insight to your inbox every month.

October 2022 was an active month for enforcement, with the Department of Treasury updating Committee on Foreign Investment in the United States (CFIUS) guidelines and the Departments of Justice (DOJ) and Commerce (DOC) taking multiple actions. To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our international trade team. We welcome your feedback and encourage sharing this newsletter with anyone who may be interested.

Continue Reading International Trade Enforcement Roundup – October 2022

On October 20, the Committee on Foreign Investment in the United States (CFIUS) released new, non-binding Enforcement and Penalty Guidelines (Guidelines). The Guidelines follow upon last month’s Executive Order linking CFIUS reviews directly to the president’s national security prerogatives. In particular, the Guidelines detail the following:

  • Categories of conduct that constitute violations.
  • Sources of information CFIUS relies upon to determine whether a violation has occurred.
  • The process for developing and imposing penalties.
  • Aggravating and mitigating factors that CFIUS evaluates when deciding whether to impose a penalty.


Continue Reading New CFIUS Guidelines Reflect Shift in Enforcement Posture

On October 7, the Department of Commerce, Bureau of Industry and Security (BIS), announced new controls on exports to China related to semiconductors. BIS also added 38 Chinese entities to the Unverified List (UVL) and established new criteria for adding entities to the Entity List. Specific details of these rules, particularly the expansive action regarding semiconductors, are laid out below.

Continue Reading Commerce Issues Two Rules Impacting China Exports, Parties

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and export restrictions as of Monday, October 3. This post supplements our previous summaries, which are available by following the links at the end of this blog post.

Commerce Adds Iranian Aircraft to List of Aircraft Operated in Violation of the EAR

On September 19, the Commerce Department’s Bureau of Industry and Security (BIS) updated its growing list of aircraft that have flown into Russia and/or Belarus in apparent violation of the Export Administration Regulations (EAR). As discussed previously, these aircraft are essentially off limits for any person to service (or operate), given that nearly any dealing with respect to such an aircraft would violate General Prohibition 10 of the EAR.

Continue Reading Russia, Ukraine: Update as of October 3