You are reading the May 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
- May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian sanctions. The U.S. government also expanded the breadth of export controls and sanctions against Russia as over 300 individuals or entities were designated or identified for blocking. Additionally, the Department of Commerce Bureau of Industry and Security (BIS) added 71 entities to its Entity List.
- There were also a few China-related enforcement actions. A former Apple employee was charged with stealing trade secrets related to autonomous tech before fleeing the country. Also, a Chinese national working for Sinotech Dalian Carbon and Graphite Manufacturing Corporation, an entity previously designated by the Treasury Department’s Office of Foreign Assets Control (OFAC), was charged with conspiring to export a material used in the development of ballistic missiles to Iran.
- In addition, Murad, LLC, a cosmetic company acquired by Unilever in 2015, was fined over $3 million for its continued violations of the Iranian sanctions regimes. OFAC also settled an investigation alleging Poloniex, LLC, an online trading platform, committed thousands of violations of multiple sanctions regimes, resulting in $7,591,630 in penalties.
- A Pennsylvania man was convicted of numerous federal offenses related to dealings with a weapons factory in the Kurdistan region of Iraq . The man violated the International Emergency Economic Powers Act (IEEPA) and Arms Export Control Act (AECA) and committed wire fraud and money laundering. He also became the second person in history to be convicted of the Federal Torture Statutes.
- May also saw the first antiboycott action since the Commerce Department strengthened its enforcement policy. A Dubai company failed to report a number of boycott requests in violation of the statute.