You are reading the June 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

  • June saw two noteworthy Russia-related enforcement actions. First, a former U.S. service member was sentenced to prison for exporting defense articles to Russia without the required license. Second, a Swedbank AB subsidiary agreed to pay more than $3 million to resolve almost 400 apparent violations of U.S. sanctions related to Russian-occupied Crimea.
  • There were also a few China-related actions. June marked the one-year anniversary of the Uyghur Forced Labor Prevention Act (UFLPA) going into effect, and the Department of Homeland Security (DHS) made its first addition to the UFLPA entity list. The Commerce Department’s Bureau of Industry and Security (BIS) also added several entities to its Entity List for strengthening Chinese military capabilities.
  • In addition, a Maryland man pled guilty to illegally exporting firearms to Ghana and faces a maximum of 20 years in prison. Also, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated its first entities under EO 14098, which allows the agency to designate entities and persons in Sudan connected to the armed conflict in that country.
  • June also saw a multilateral agreement between Five Eyes partners to improve information sharing to close gaps in export control enforcement and increase administration capacity. Additionally, the Departments of Justice, Commerce, State and Treasuryissued a joint advisory to alert private industry of their obligations related to export control laws in the UAV sector.

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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.