International Trade Enforcement

On January 7, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Order resolving allegations that Exyte Management GmbH (Exyte), a Germany-based company, committed 13 violations of the Export Administration Regulations (EAR) in China. The violations were committed by Exyte’s Chinese affiliate, Exyte Shanghai Ltd (Exyte China).Continue Reading Export Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty

We hope everyone had a great holiday. 2026 is now officially off and running, and particularly in light of recent events, we want to briefly summarize current trade restrictions related to Venezuela. The landscape will almost certainly shift soon – and often – and we will provide updates as often as possible. Importantly, at present, there continue to be significant restrictions when doing business in and with Venezuela.Continue Reading Update on Venezuela: Significant Trade Restrictions and Risks Continue

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced two separate enforcement actions against IPI Partners, LLC and Gracetown, Inc. for violations of Ukraine-/Russia-related sanctions. OFAC is the agency responsible for administering and enforcing U.S. economic sanctions programs.

These actions highlight OFAC’s willingness to scrutinize private equity and other investment

On July 28, various arms of the U.S. government announced concurrent export enforcement resolutions involving Cadence Design Systems, Inc. (Cadence), a California-based software and technology firm. Cadence will pay over $140 million in combined net criminal and civil penalties and forfeiture.Continue Reading Huge Export Penalty for U.S. Technology Company

In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. OFAC is the primary U.S. government agency that administers and enforces U.S. sanctions.Continue Reading Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the world. Continue Reading Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty

I’m excited to kick off the American Conference Institute’s 14th Annual Advanced Forum on Global Export Controls with a pre-conference workshop on February 24, 2025, from 1:30–5:00 PM. Together with Sarah York, Senior Counsel for International Trade Compliance at GE Aerospace, I’ll lead Workshop B – An Updated Roadmap on Making High Stakes, Time-Sensitive Decisions.

This interactive, small-group session will tackle critical compliance challenges, including:Continue Reading Join Us for a Pre-Conference Workshop at the Global Export Controls Forum