You are reading the July 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

  • July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on behalf of the Russian government. In addition, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on entities and individuals to limit Russian access to U.S. technology and disrupt the Russian economy.
  • There was also a major China-related enforcement action. An indictment was unsealed alleging that a dual U.S.-Israeli citizen flouted foreign agent registration requirements and sought to broker weapons deals between Chinese companies and foreign governments.
  • An Iranian national who is a resident of Virginia was sentenced to 41 years in prison for violating U.S. sanctions on Iran.
  • The Commerce Department imposed penalties against two companies that violated U.S. antiboycott regulations while attending a Bahrain trade show. Commerce also announced “two measures to further expand [its] antiboycott enforcement efforts.”
  • OFAC extended a general license covering the export and re-export of liquefied petroleum gas to Venezuela with some tweaks.
  • The Departments of Justice, Commerce, and Treasury issued a tri-seal notice to provide guidance on the process for voluntary self-disclosure of potential violations of export controls, sanctions, and other national security laws.

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Photo of Faith Dibble Faith Dibble

Faith Dibble counsels clients as they navigate the complex regulations associated with a global marketplace. She advises clients on international trade and complex cross-border transactions, investigations, and regulatory and compliance matters relating to U.S. national security.

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.