You are reading the April 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.
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Overview
- April saw continuing enforcement actions involving Russia. Four individuals across three different enforcement actions pleaded guilty or were sentenced to time in prison resulting from illegal exports of controlled items to Russia. Two of these actions specifically involved the Disruptive Technology Strike Force run by the Department of Justice (DOJ) and the Commerce Department, and the DOJ’s Task Force KleptoCapture.
- There was also a notable action involving China this month. The DOJ charged two Chinese nationals with attempting to export semiconductor equipment to a party designated on the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (BIS).
- In addition, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled with a Thai plastics company for violating U.S. sanctions on Iran.
- Other enforcement actions showcased the range of penalties and violations that U.S. enforcement authorities are pursuing. In one case, an individual was sentenced to 70 years in prison for torture and associated violations of export control laws. In another, two foreign national arms dealers were charged with attempting to unlawfully export weapons from the United States.
- Lastly, there were two new regulatory changes in April. First, a provision of the “National Security Supplement,” signed into law on April 24, expands the statute of limitations under the International Emergency Economic Powers Act (IEEPA) and Trading with the Enemy Act (TWEA) from five to ten years. Second, the DOJ announced a new Voluntary Self-Disclosure Pilot Program tailored to individuals.