You are reading the March 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

  • March saw one major enforcement action related to Russia. Oleg Chistyakov, a Latvian national, was arrested and charged for allegedly exporting U.S.-origin aircraft technology to Russia.
  • There were notable actions involving the International Traffic in Arms Regulations (ITAR). First, a U.S. Army Intelligence Analyst was charged for illegally exporting national defense information to China. Second, a California man was charged with attempting to export defense articles to Oman.
  • March also saw a notable sanctions enforcement action involving EFG International AG, a Switzerland-based bank, which agreed to pay almost $4 million to settle allegations it had violated U.S. sanctions programs administered by the U.S. Treasury Department, Office of Foreign Assets Control (OFAC).
  • In addition, there were two notable Foreign Corrupt Practices Act (FCPA) enforcement actions in March. First, Gunvor S.A., a Switzerland-based international commodities company, pleaded guilty and agreed to pay more than $650 million to resolve a Department of Justice (DOJ) investigation. And the former Finance Director of Stericycle—a company that was itself targeted by the DOJ in 2022—was indicted for his role in bribing government officials in Argentina, Brazil, and Mexico.
  • Lastly, the U.S. government issued a new rule expanding existing end-user requirements and a tri-seal compliance note that further underscore the extent to which U.S. export controls and sanctions can apply to non-U.S. actors.

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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.