On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S. sanctions, export controls, and other national security laws. Continue Reading Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury
International Trade
[WEBINAR] Conducting Clinical Trials Outside the U.S.: U.S. and Foreign Rules, Regulations, and Guidance
We will speak at a Strafford webinar providing guidance to life sciences companies and research institutions that are conducting or considering conducting clinical trials outside the United States.Continue Reading [WEBINAR] Conducting Clinical Trials Outside the U.S.: U.S. and Foreign Rules, Regulations, and Guidance
[WEBINAR] Significant EAR Violations and BIS Policy Shift: Incentivized Voluntary Self-Disclosure, Third-Party Whistleblowing
I am looking forward to speaking on a panel at an upcoming Strafford webinar addressing the U.S. Department of Commerce’s recent policy shift that increases the incentives for companies to voluntarily self-disclose (VSD) possible EAR violations, particularly when “significant,” or risk serious penalties. Continue Reading [WEBINAR] Significant EAR Violations and BIS Policy Shift: Incentivized Voluntary Self-Disclosure, Third-Party Whistleblowing
International Trade Enforcement Roundup – June 2023 Update

You are reading the June 2023 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 – June 2023 Update
International Trade Enforcement Roundup – May 2023 Update
You are reading the May 2023 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 – May 2023 Update
Updates to FCPA and Impact for Healthcare Companies
We co-authored an article for Compliance Today with Channing Landreth, the associate vice president and managing counsel at Labcorp, to summarize how recent developments related to the Foreign Corrupt Practices Act (FCPA) impact healthcare companies. Continue Reading Updates to FCPA and Impact for Healthcare Companies
International Trade Enforcement Roundup – April 2023 Update
You are reading the April 2023 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 – April 2023 Update
FCPA Enforcement: New Corporate Enforcement Policy, Aggressive Enforcement, and Lessons Learned From Recent Resolutions
Please join us for a lively and timely discussion of recent FCPA enforcement activity on Tuesday, May 23, 2023 at 1pm ET/12pm CT.Continue Reading FCPA Enforcement: New Corporate Enforcement Policy, Aggressive Enforcement, and Lessons Learned From Recent Resolutions
International Trade Enforcement Roundup – March 2023
You are reading the March 2023 edition 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 – March 2023
Department of Defense to Require Contractors Proactively Provide DCMA with Export Authorizations
On March 22, the Department of Defense (DOD) issued a proposed rule that would amend the Defense Federal Acquisition Regulations (DFARS) to require certain contractors to provide the Defense Contract Management Agency (DCMA) with relevant export authorizations (i.e., export licenses, exemptions, or exceptions). Currently, contractors are only required to make their export authorizations available for DCMA personnel to review at the contractor’s site. This rule would change that by shifting the burden to federal contractors.
Continue Reading Department of Defense to Require Contractors Proactively Provide DCMA with Export Authorizations
