Sanctions
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DDTC Consent Agreement Highlights Technical Data Export Challenges

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…

night image of network of lights with buildings in the background Settlements Exports Controlled - Software Encryption
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Settlements for Exports of Controlled Encryption Software to Iran

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…

OFAC
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More Apparent OFAC Violations Involving Foreign Subsidiary Companies

Parenting can be such a chore.  Minding wayward little ones, cleaning up after them, and getting hit with six-figure Treasury Department penalties for their misbehavior can offset the joy of beholding the smiles on their cherubic faces. Did I say Treasury Department penalties? Yes, they can arise when the parent is a U.S.-based company and…