I learned a new word recently: “goat-rope.” The safe-for-work definition is a big, confusing mess. While it can be used to describe many different situations, I thought it was a perfect description for the ways in which the United States makes origin determinations for products imported from Canada and Mexico. Fortunately, help to make things…
Three Florida residents have been charged in federal district court in Miami with crimes related to their alleged violations of U.S. sanctions on Iran, and money laundering. Defendants Mohammad Faghihi, 52, his wife Farzeneh Modarresi, 53, and his sister Faezeh Faghihi, 50, operated Florida company Express Gene. According to the criminal complaint affidavit, between October…
KUALA LUMPUR, Malaysia (AP) — Malaysia’s government pledged July 5, 2021, to take steps to eliminate forced labor after the country was downgraded by the U.S. to the worst level in an annual report on human trafficking. Human Resources Minister M. Saravanan said the government is taking the downgrade seriously and has ramped up efforts…
Mexico is seeking formal consultations with the U.S. over rules for cars shipped across regional borders under a year-old trade agreement as it seeks to de-escalate a conflict that emerged last month. The Mexican government wants the talks in order to avoid or settle a potential dispute over the requirements the U.S. is imposing on…
Part 129 of the International Traffic in Arms Regulations (“ITAR”) requires certain persons engaged in “brokering activities” to register with and pay a fee to, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”). ITAR Part 129.2 broadly defines “broker” as any person engaging in “brokering activities” (discussed in greater detail below) fitting…
A California man was sentenced today to 63 months, or more than five years, in prison for his role in a scheme to illegally export integrated circuits with military applications to China the required filing of electronic export information. As part of his sentence, the Judge ordered Shih to pay $362,698 in restitution to the…
It’s my long-held position that technology controls present the most challenging export compliance challenge. Last month’s consent agreement between the Directorate of Defense Trade Controls and Honeywell International illustrates my point quite well. As we’ll discuss, Honeywell fell into three of the most common traps for unauthorized exports of controlled information. Companies subject to the International Traffic…
A federal grand jury in Los Angeles unsealed an indictment Thursday that accuses five defendants of conspiring to unlawfully export defense articles to Russia. Specifically, the defendants allegedly exported thermal imaging riflescopes and night-vision goggles without a license, in violation of the Arms Export Control Act. According to court documents, Elena Shifrin, 59, of Mundelein,…
OFAC and BIS regulations SAP, a German multinational software corporation with a significant U.S. presence, recently settled allegations that it violated OFAC and BIS regulations concerning exports of software, upgrades, and patches from the United States to Iran and Iranian companies. The settlement amounts totaled in excess of $6.4 million. In the following transcript George…
A Transformative Approach for the Future of Trade Since the last comprehensive trade legislation reforms in 1993, growth in e-commerce, rapid technological change, and the continued expansion of the global marketplace have significantly altered how trade is conducted. As these shifts continue to accelerate and evolve, it is imperative for the U.S. Government to act now to pursue transformational reforms…
Although historically less attention-grabbing than sanctions, US export controls have been progressively newsworthy in recent years–starting with the Trump administration’s headlining restrictions aimed at Huawei, initiated in May 2019. More recently, the US government’s focus on China’s military modernization appears to have a driven a spate of China-focused export controls launched by the US Department…
