You are reading the September 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

  • John Deere agreed with the Securities and Exchange Commission (SEC) to pay nearly $10 million related to Foreign Corrupt Practices Act (FCPA) violations resulting from conduct of a Thai subsidiary.
  • The Department of Justice (DOJ) announced five trade enforcement matters resulting from the efforts of the Disruptive Technology Strike Force.
  • The Bureau of Industry and Security’s (BIS) Office of Information and Communications Technology and Services (OICTS) promulgated a proposed rule that would prohibit certain transactions involving “connected vehicle” technology from the People’s Republic of China (PRC) and Russia.
  • BIS imposed a $400,000 penalty against First Call International, a global procurement and manufacturing company, for export violations.
  • The Office of Antiboycott Compliance (OAC) settled with Quantum Corporation, a data storage company, for violations of U.S. antiboycott regulations.

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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.