You are reading the January 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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- January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for illegally exporting thousands of U.S. microelectronics to Russia. Third, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated a United Arab Emirates (UAE) shipping company for violating the oil price cap.
- There were two notable actions involving Iran this month. The Department of Justice (DOJ) charged four Chinese nationals with illegally procuring U.S.-origin products for Iranian efforts to produce unmanned aerial vehicles (UAVs) and ballistic missiles. Also, a U.S. citizen was sentenced to two years in prison for improperly exporting heavy machinery to Iran using the UAE as a transshipment point.
- BIS imposed a $153,175 penalty against Wabtec Corporation for violations of the antiboycott regulations—an unusually large penalty in the context of boycott enforcement.
- SAP SE, a global software company, entered into a Deferred Prosecution Agreement (DPA) with the DOJ and resolved a Securities and Exchange Commission (SEC) investigation into bribery schemes involving a number of countries in Africa, Indonesia, and elsewhere in violation of the Foreign Corrupt Practices Act (FCPA).
- Lastly, a new BIS policy announced several “key updates” to BIS’s Voluntary Self-Disclosure (VSD) process and hinted at increased penalties for export control violations going forward.