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On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying with U.S. sanctions and export control laws as well as recent enforcement actions. This may signal more scrutiny on the compliance of foreign companies which we have discussed here.Continue Reading Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal Compliance Note on Foreign Based Persons’ Obligations to Comply with U.S. Sanctions and Export Control Laws

We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance.  From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the overall need for compliance.  On a more granular level, enforcement actions provide valuable insight into how the government thinks about and targets violations of law.  These cases also showcase key details about international business practices that might pose “red flags,” and let us learn from others’ mistakes.  Effective compliance requires companies to commit high-level attention and large dollar amounts, but also requires entities to critically respond to the facts and details of particular markets on the ground.
Continue Reading Don’t try this at Home or Abroad: Export Controls and Sanctions Violations Lead to $21 Million in Penalties for Dutch Company Fokker Services B.V.