You are reading the January 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

  • January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for illegally exporting thousands of U.S. microelectronics to Russia. Third, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated a United Arab Emirates (UAE) shipping company for violating the oil price cap.
  • There were two notable actions involving Iran this month. The Department of Justice (DOJ) charged four Chinese nationals with illegally procuring U.S.-origin products for Iranian efforts to produce unmanned aerial vehicles (UAVs) and ballistic missiles. Also, a U.S. citizen was sentenced to two years in prison for improperly exporting heavy machinery to Iran using the UAE as a transshipment point.
  • BIS imposed a $153,175 penalty against Wabtec Corporation for violations of the antiboycott regulations—an unusually large penalty in the context of boycott enforcement.
  • SAP SE, a global software company, entered into a Deferred Prosecution Agreement (DPA) with the DOJ and resolved a Securities and Exchange Commission (SEC) investigation into bribery schemes involving a number of countries in Africa, Indonesia, and elsewhere in violation of the Foreign Corrupt Practices Act (FCPA).
  • Lastly, a new BIS policy announced several “key updates” to BIS’s Voluntary Self-Disclosure (VSD) process and hinted at increased penalties for export control violations going forward.

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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.