You are reading the February 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

  • February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number of sanctions imposed since Russia’s full-scale invasion of Ukraine.” The Commerce Department’s Bureau of Industry and Security (BIS) also added 93 entities to its Entity List. Second, the Department of Justice (DOJ) disrupted two separate sanctions evasion schemes with individuals entering guilty pleas.
  • There were three notable actions involving Iran this month. BIS reached an administrative settlement with CargoSave, a freight shipper, which seems to have been granted “credit” for assisting in an investigation of a third party. Also, a UK citizen was sentenced to 18 months in prison for conspiring to export U.S.-origin goods to Iran, and a father-son duo was charged with facilitating the export of a variety of U.S.-origin equipment and technology to Iran.
  • February also saw a flurry of enforcement actions involving China. Boeing agreed to settle 199 Violations of the International Traffic in Arms Regulations (ITAR) when it allowed foreign person employees (FPEs), some residing in China, access to ITAR-controlled files on an internal server. And a U.S. citizen pleaded guilty to conspiring to commit wire fraud after he sourced parts and components from China in violation of contracts with the U.S. government.

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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.