On August 24, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $1 million settlement with Ohio-based Container Manufacturing Ltd. (CML) to resolve allegations that the company exported restricted industrial parts to Russia without authorizations required under the Export Administration Regulations (EAR). According to BIS, the violations occurred between March 2023 and March 2025, and included parts valued at approximately $265,000. Notably, two of the shipments involved violations made with knowledge, which may explain a penalty amount nearly four times the value of the underlying transactions.
Continue Reading BIS Settlement Highlights Russia Export Control Risks for EAR99 Items and Third-Country Transactions
Thad McBride
Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.
BIS Settlement Highlights Export Control Risks for Medical and Research Technology
On August 14, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Plexon, Inc., a Texas neuroscience technology company. BIS asserts that Plexon exported neural recording systems to a restricted Chinese research institution without appropriate authorization under the U.S. Export Administration Regulations (EAR). The EAR is the set of regulations that control exports of U.S. dual-use items; BIS is the main government agency responsible for administering and enforcing the EAR.
Continue Reading BIS Settlement Highlights Export Control Risks for Medical and Research Technology
OFAC Settlement Highlights Iran Sanctions Risks for Non-U.S. Subsidiaries of U.S. Companies
On August 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $60,764 settlement with Rice Lake Weighing Systems (Rice Lake), a Wisconsin-based manufacturer of scales and other weight measuring equipment, to address apparent violations of U.S. sanctions on Iran. The violations were committed by Dini Argeo S.r.l. (Dini), Rice Lake’s Italian subsidiary.
Continue Reading OFAC Settlement Highlights Iran Sanctions Risks for Non-U.S. Subsidiaries of U.S. Companies
DOJ’s First FCPA Deferred Prosecution Agreement of 2026 Highlights Cartel-Linked Corruption Risks
On July 17, the U.S. Department of Justice (DOJ) announced that The Scoular Company (Scoular), a Nebraska-based agricultural supply chain company, agreed to pay more than $10 million to resolve allegations that it used third-party customs brokers to bribe Mexican officials facilitating shipments across the U.S.-Mexico border.
Continue Reading DOJ’s First FCPA Deferred Prosecution Agreement of 2026 Highlights Cartel-Linked Corruption Risks
OFAC Launches Reconsideration Portal to Streamline Delisting Petitions
On June 29, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) launched an online Reconsideration Portal for requests to remove persons or property from OFAC sanctions lists, including the Specially Designated Nationals and Blocked Persons (SDN) List. OFAC states that the portal streamlines delisting petitions by collecting key information upfront rather than through repeated questionnaires.…
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DOJ Issues First Corporate Enforcement Policy Declination: Lessons from Bosch’s FDPR Export Control Resolution
On June 17, the U.S. Department of Justice (DOJ) National Security Division (NSD) announced its first declination under the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), declining to prosecute Robert Bosch GmbH (Bosch) for potential criminal violations of the Export Control Reform Act (ECRA).
FinCEN Proposed Rulemaking: Significant Revisions Centered on Risk, Effectiveness, and Supervisory Consistency
On April 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Press Release describing a Notice of Proposed Rulemaking that would significantly reshape anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements across a wide range of financial institutions. Comments are due by June 9, 2026.
Continue Reading FinCEN Proposed Rulemaking: Significant Revisions Centered on Risk, Effectiveness, and Supervisory ConsistencyFTC Signals Renewed “Made in USA” Enforcement Focus Following Trump Executive Order
Recent “Made in USA” enforcement actions show that U.S.-origin claims continue to be an active enforcement priority for the Federal Trade Commission (FTC). On April 14, the FTC announced three enforcement actions and the closure of two investigations involving companies alleged to have overstated the domestic origin of their products. The announcement followed a March 13 Executive Order (the “EO”) calling for heightened scrutiny of purportedly false “Made in America” representations.
Continue Reading FTC Signals Renewed “Made in USA” Enforcement Focus Following Trump Executive OrderExport Compliance in Line with Recent BIS Civil Penalty
We co-authored an article for Corporate Compliance Insights discussing a recent case in which the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a penalty against Applied Materials (AMAT) for $253 million, the second-largest civil penalty in BIS history.
Continue Reading Export Compliance in Line with Recent BIS Civil PenaltyFinCEN Advisory Warns Financial Institutions of Healthcare Fraud Targeting Medicare and Medicaid
At the end of March, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory urging financial institutions to heighten scrutiny of transactions potentially tied to healthcare fraud schemes targeting Medicare, Medicaid, and other federal and state healthcare benefit programs. The Advisory is accompanied by this press release.
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