You are reading the December 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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Overview

  • December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance company and California-based virtual currency exchange. In addition, a Belgian national was indicted by the Department of Justice (DOJ) and designated by OFAC after conspiring to illegally procure products for resale in Russia and China.
  • There were two notable actions involving Iran this month. The DOJ charged two individuals for allegedly procuring U.S.-origin microelectronics for an Islamic Revolutionary Guard Corps (IRGC) drone program. Also, OFAC agreed with Nasdaq to settle an investigation of sanctions violations committed by Nasdaq’s Armenian subsidiary.
  • The DOJ entered into a Deferred Prosecution Agreement (DPA) with Freepoint Commodities, a Connecticut-based commodities trader, for bribing officials at Petróleo Brasileiro S.A. (Petrobras), a Brazilian state-owned oil company, in violation of the Foreign Corrupt Practices Act (FCPA).
  • Lastly, a new Executive Order gives the Secretary of Treasury broader authority to take enforcement actions against foreign financial institutions (FFIs), and the Departments of Commerce, Homeland Security, Justice, State, and Treasury issued a first-ever joint note on compliance best practices for the maritime and transportation industry.

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Photo of Thad McBride Thad McBride

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP)…

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.