In our latest article for The National Law Journal, we examine the U.S. Department of Justice’s recent Bosch declination and what it reveals about DOJ’s approach to export controls enforcement, compliance program effectiveness, and voluntary self-disclosure decisions.
Continue Reading DOJ’s Bosch Declination Offers a Practical Export Controls Compliance and Voluntary Disclosure RoadmapInternational Trade
BIS Settlement Highlights Russia Export Control Risks for EAR99 Items and Third-Country Transactions
By Faith Dibble & Thad McBride on
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
BIS Settlement Highlights Export Control Risks for Medical and Research Technology
By Faith Dibble & Thad McBride on
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
By Thad McBride on
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
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 Sectors