You are reading Bass, Berry & Sims’ February 2023 edition of our Monthly Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox every month.
To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any of the actions mentioned and how they relate to your business, contact our firm’s international trade team. We welcome your feedback and encourage sharing this newsletter with anyone interested.
February saw several interesting enforcement actions. From a Chinese “spy balloon’s” cross-country journey to the first anniversary of the war in Ukraine, the news of the day seemed to drive much of the enforcement activity. Let’s get into it!
- Twelve months after the beginning of the war in Ukraine, economic sanctions and export controls imposed on Russia and regions of Ukraine have fundamentally altered international commerce. As in prior months, Russia-related actions were plentiful. Notably, a Russian national was indicted for illegally smuggling controlled goods for Russia’s Federal Security Service (FSB) and North Korea, and an associate of oft mentioned Viktor Vekselberg was indicted for maintaining Vekselberg’s U.S. properties.
- China enforcement actions slowed but did not cease. A 3D printing company with U.S. government contracts was ordered to pay up to $27 million for violations of the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and False Claims Act (FCA) for illegal exports of technical data. And after the U.S. government recovered and examined the infamous Chinese weather balloon, the Department of Commerce’s Bureau of Industry and Security (BIS) placed six Chinese entities on the Entity List (EL).
- Austria and Switzerland make their way onto our Roundup for the first time as Dotphins, an e-commerce platform, illegally exported – and attempted to export – red dot scopes to the two countries in violation of the EAR.
- Iran was also involved in several enforcement actions. For one, a dual American-Iranian citizen exported controlled items to the National Bank of Iran in violation of U.S. export controls. In addition, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated nine entities operating in the Iranian petrochemical industry and eight senior directors of Paravar Pars Company, an Iranian drone manufacturer.