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.
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- We saw several notable Russia-related enforcement actions in April, with two centered on the associates of Russian oligarchs – one of whom was a New York-based lawyer. Also, the Department of Justice (DOJ) announced the fine for an Estonian entity that illegally attempted to re-export a jig grinder to Russia, and Microsoft was fined after alleged violations of several sanctions and export restrictions.
- Iran was also the focus of an enforcement action in April as DOJ prosecuted a woman who used Venmo, a financial services app, to help the Iranian regime facilitate a kidnapping plot of a prominent U.S.-based journalist.
- We also saw a number of North Korea-related actions. British American Tobacco was fined over $600 million for violating the North Korean sanctions program via a foreign subsidiary. And multiple individuals were indicted for their roles in using cryptocurrencies to launder money for the North Korean regime.
- In China-related news, Seagate, an American data storage company, agreed to resolve over 400 violations of the Export Administration Regulations (EAR) that occurred when it sold hard disk drives to Huawei after Huawei’s addition to the Entity List.
- And the Commerce Department, Bureau of Industry & Security (BIS) released a new enforcement policy that should further encourage companies to voluntarily disclose violations of export control laws. The new policy also includes incentives for companies to disclose possible violations by third parties, including competitors.