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
International Trade Enforcement
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
By Faith Dibble & Thad McBride on
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.…
Continue Reading OFAC Launches Reconsideration Portal to Streamline Delisting Petitions
DOJ Issues First Corporate Enforcement Policy Declination: Lessons from Bosch’s FDPR Export Control Resolution
By Faith Dibble & Thad McBride on
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).
FTC Signals Renewed “Made in USA” Enforcement Focus Following Trump Executive Order
By Faith Dibble & Thad McBride on
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
By Faith Dibble & Thad McBride on
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 PenaltyExport Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China
By Faith Dibble & Thad McBride on
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 ChinaOFAC 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 SectorsExport Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty
By Faith Dibble & Thad McBride on
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 PenaltyUpdate on Venezuela: Significant Trade Restrictions and Risks Continue
By Faith Dibble & Thad McBride on
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