On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The private whistleblower who reported the conduct received over $1.2 million in the matter. As we suggested in a blog post in February, these sorts of enforcement actions will proliferate under the Trump DOJ.Continue Reading DOJ Settlement Highlights Customs, FCA Risks for Importers
America First Investment Policy Sets Sights on China
On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and Macau (collectively, the PRC), in sensitive U.S. sectors, modifies aspects of the Committee for Foreign Investment in the United States (CFIUS) process, and proposes new restrictions on outbound investment. Continue Reading America First Investment Policy Sets Sights on China
Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil liability related to multiple violations of the Ukraine-/Russia-related Sanctions Regulations and the Export Administration Regulations (EAR). Continue Reading Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
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
Key Compliance Considerations for U.S. Investors Under the Treasury’s New Outbound Investment Regulations
In an article for Law360, I summarized the U.S. Department of Treasury’s new outbound investment regulations and outlined key compliance considerations for U.S. investors. I explained that the rule “aims to prevent U.S. capital and less tangible benefits like managerial services from accelerating the development of certain technologies that could harm U.S. security interests.”Continue Reading Key Compliance Considerations for U.S. Investors Under the Treasury’s New Outbound Investment Regulations
Watch Now | Managing Forced Labor and Other Supply Chain Compliance Challenges Webinar
As global supply chains continue to expand, it is essential to understand the legal, compliance, and practical challenges that arise. Forced labor, economic sanctions, corruption, and other risks can be significant, especially when relying on suppliers in China and the developing world. The early actions of the new Trump administration, and the responses from trading partners, make these challenges even more pronounced.Continue Reading Watch Now | Managing Forced Labor and Other Supply Chain Compliance Challenges Webinar
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
German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran
Key Points:
- Long-arm of U.S. sanctions jurisdiction reaches conduct by European company.
- Violation involved shipment to Iran from Australia, a close U.S. ally.
On December 3, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that Aiotec GmbH, a German supplier of industrial equipment for the energy sector, agreed to pay $14,550,000 to settle its potential civil liability for violating the Iranian Transactions and Sanctions Regulations (ITSR). The settlement agreement can be found here. The press release can be found here.Continue Reading German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran
International Trade Enforcement Roundup – November 2024
You are reading the November 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 – November 2024
Join Us for a Pre-Conference Workshop at the Global Export Controls Forum
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