On February 11, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Applied Materials, Inc. (AMAT) and Applied Materials Korea, Ltd. (AMK) resolving allegations that the companies illegally reexported U.S.-origin semiconductor manufacturing equipment to China. Continue Reading Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China
OFAC Enforcement Update: $1.72M Settlement Highlights Screening Gaps in Education, Similar Sectors
On February 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $1.72 million settlement with IMG Academy, LLC (IMG) arising from apparent violations of OFAC’s counternarcotics sanctions program. OFAC is the U.S. government agency with primary responsibility for administering economic sanctions.Continue Reading OFAC Enforcement Update: $1.72M Settlement Highlights Screening Gaps in Education, Similar Sectors
Export Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty
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
Update on Venezuela: Significant Trade Restrictions and Risks Continue
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
OFAC Enforcement Update: Recent Penalties Highlight Expectations Around Beneficial Ownership, Transparency, and Reporting Obligations
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
Huge Export Penalty for U.S. Technology Company
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
Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure
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
U.S. Government Eases Some Restrictions on Syria
On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S. economic sanctions.Continue Reading U.S. Government Eases Some Restrictions on Syria
Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty
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
International Trade Enforcement Roundup – December 2024
You are reading the December 2024 Update of the 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.Continue Reading International Trade Enforcement Roundup – December 2024