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December was a busy month! A highly complex Russian procurement network dismembered, a former Marine indicted, a government contractor sentenced to prison for export violations, and temporary denial orders (TDOs) galore! Let’s get into it.
- December saw a flurry of Russia-specific enforcement actions. The Department of Justice (DOJ) indicted a sanctions evader using new criminal forfeiture powers for the first time and interrupted a sophisticated Russian procurement network that had been violating numerous export regulations. Additionally, the Department of Commerce’s Bureau of Industry and Security (BIS) renewed several TDOs against Russian and Belarusian airlines.
- DOJ took action against a former Marine who violated the International Traffic in Arms Regulations (ITAR) when he provided training to Chinese military pilots. BIS also renewed a TDO on Quicksilver Manufacturing, Inc., Rapid Cut LLC, and US Prototype, Inc. based on evidence that the companies were continuing to send unauthorized exports to China.
- The Department of Treasury’s Office of Foreign Assets Control (OFAC) settled with Danish manufacturer Danfoss A/S for violating U.S. sanctions on Iran, Sudan, and Syria.
- Another government contractor was in the news. A Massachusetts man was sentenced to prison following the illegal export of defense technical information to Turkey.
- The DOJ and the Securities & Exchange Commission (SEC) announced several significant settlements involving matters under the Foreign Corrupt Practices Act.