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International Trade Enforcement Roundup – October 2023 Update

By Faith Dibble & Thad McBride on November 9, 2023
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You are reading the October 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.

To stay up to date, subscribe to our GovCon & Trade blog. If you have questions about any actions addressed in the Roundup, please contact the international trade team. We welcome your feedback and encourage you to share this newsletter. Let’s jump in!

Link to Overview Overview

  • October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading company pleaded guilty to sanctions violations for transacting with a designated Russian oligarch.
  • There were also several notable U.S. sanctions matters in October. The U.S. Treasury Department Office of Foreign Assets Control (OFAC) issued two tranches of sanctions targeting Hamas financial networks. In addition, U.S. sanctions on Venezuela were eased through the issuance of four General Licenses (GLs). And a U.S. citizen pleaded guilty to violating the International Emergency Economic Powers Act (IEEPA) for exceeding the scope of an OFAC license related to Iran.
  • October also saw a number of enforcement policy updates. The Departments of Justice, Commerce, State and Treasury issued an advisory alert detailing the threats posed by Iran’s procurement efforts for its ballistic missile programs. In addition, after issuing rules in 2022 to control various types of advanced semiconductors, the Commerce Department’s Bureau of Industry and Security (BIS) issued new rules strengthening and clarifying those requirements.

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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.

Read more about Faith DibbleEmail
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.

Read more about Thad McBrideEmail
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  • Posted in:
    Government Contracts
  • Blog:
    GovCon & Trade
  • Organization:
    Bass, Berry & Sims PLC
  • Article: View Original Source

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