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January saw a bevy of interesting enforcement actions and regulatory policy changes. A high-level former FBI agent was charged with sanctions violations, for the first time ever a North Korean national was extradited to the U.S. for money laundering to benefit designated persons, and yet another instance of Chinese espionage was thwarted. Let’s jump in!

Overview

  • January was a busy month for Russia-specific enforcement actions. Charles McGonigal, former Special Agent in Charge of the high profile FBI New York Counterintelligence Division, was indicted by the Department of Justice (DOJ) in connection with alleged work for a designated Russian oligarch. A Russian and a British national were also charged for supporting another Russian oligarch in maintaining his $90 million, 250-foot mega yacht.
  • The DOJ nabbed another U.S. citizen engaged in economic espionage involving China and the aerospace industry. According to the DOJ, Jonathan Yet Wing Soong – a program administrator at the Universities Space Research Association (USRA), a U.S. nonprofit research organization – conspired to illegally export aircraft modeling software to a Chinese university
  • A North Korean national was extradited and charged with falsifying transaction records and using shell companies to illegally transfer over $1.2 million to raise capital and buy consumer goods and other commodities for North Korea. This was the first time a North Korean National was extradited to the U.S. after being charged.
  • A U.S. citizen was charged with illegally shipping petroleum products into and out of Iran in violation of U.S. sanctions on Iran. Seven Iranian drone producers were also designated pursuant to the Russia/Belarus-Military End User Foreign Direct Product Rule.
  • The Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy (CEP), now dubbed the Corporate Enforcement and Voluntary Self Disclosure Policy, got a significant facelift in January.

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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.