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Submitting Voluntary Self-Disclosures to Bureau of Industry & Security

Diaz Trade Law is enthusiastic to announce Bloomberg Law published an update to our previous article, “Submitting Voluntary Self-Disclosures to Bureau of Industry & Security.” The udpate discusses new guidance from BIS regarding failure to voluntary disclose significant violations. Below is the article reproduced with permission for your reading pleasure. You can read the article here (where you’ll have the ability to access all of the great hyperlinks). Please note you cannot click on the hyperlinks below.

We’d love to hear your feedback!

By |2023-05-11T12:56:55-04:00May 11, 2023|Bloomberg Export|Comments Off on Submitting Voluntary Self-Disclosures to Bureau of Industry & Security
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Significant Updates to BIS Enforcement Policies in 2022

Diaz Trade Law’s President, Jennifer Diaz, Associate Attorney Sharath Patil, are enthusiastic to announce Bloomberg Law published another one of our articles, “Significant Updates to BIS Enforcement Policies in 2022“! Below is the article reproduced with permission for your reading pleasure. You can read the article here (where you’ll have the ability to access all of the great hyperlinks). Please note you cannot click on the hyperlinks below.

We’d love to hear your feedback!

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By |2022-11-08T14:42:31-05:00November 8, 2022|Bloomberg, Bloomberg Export, China, Cuba, EAR, Export, International Trade, IRAN, People's Republic of China, Russia, Russian Harmful Foreign Activities Sanctions Regulations, U.S. Bureau of Industry and Security (BIS)|Comments Off on Significant Updates to BIS Enforcement Policies in 2022
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BIS Publishes Report on Effect of Uranium Imports on National Security

Background on Section 232 Investigations – Section 232 investigations, administered by the U.S. Commerce Department, are conducted to determine the effect of imports of certain goods on national security Historically, Section 232 investigations have been conducted regarding U.S. imports of crude oil and petroleum products and uranium, among other critical imports.

Investigations may be initiated based on an application from an interested party, a request from the head of any department or agency, or may be self-initiated by the Secretary of Commerce. The Secretary’s report to the President, prepared within 270 days of initiation, focuses on whether the importation of the article in question is in such quantities, or under such circumstances, that threaten to impair the national security. The President can concur or not with the Secretary’s recommendations, and take action to “adjust the imports of an article and its derivatives” or other non-trade related actions as deemed necessary.

To learn more about Section 232 investigations including background on relevant laws and regulations and the history of past cases, check out the Section 232 Program Guide.

[…]

By |2021-10-26T12:24:39-04:00November 2, 2021|Import, Investigation, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)|1 Comment
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$432k Penalty From BIS Stresses Importance of Export Compliance

Building and maintaining a strong export compliance program is essential if you don’t want your company to become a headline. The Bureau of Industry and Security (BIS) announced an administrative settlement with a penalty amount of $432,570, for Alfa Laval US of Richmond, VA and Alfa Laval Middle East Ltd. of the United Emirates for alleged violations of the Export Administration Regulations. 

Do you know if your company is meeting export regulations and obligations? Obtaining counsel who is an expert in export compliance is the first step. Are your employees/staff trained in all exporting issues? Our one-hour webinar is a must attend to help provide you with a foundation of tools and key elements that must be included in your export compliance program. Register today to hear from the following experts: 

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By |2021-09-13T15:54:12-04:00September 14, 2021|EAR, Export, International Law, U.S. Bureau of Industry and Security (BIS), U.S. Office of Foreign Assets Control (OFAC)|1 Comment
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Understanding the GOV Export License Exception

Background on Export Administration Regulations

Over 95% of the world’s consumers are outside of the United States. Opportunities abound for U.S. companies that export. However, exporting is a privilege and not a right. U.S. exporters have an important responsibility to adhere to U.S. export control laws, including the Export Administration Regulations (“EAR”).

Administered by the U.S. Commerce Department, the EAR is a set of regulations which governs whether U.S. persons may export or transfer goods, software, and technology outside of the United States or to non-U.S. citizens. U.S. exporters have an important responsibility to adhere to the EAR. Violations of the EAR carry hefty civil and criminal penalties. Exporters can pay hundreds of thousands of dollars in penalties, lose export privileges, and even be imprisoned.

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By |2021-10-07T14:37:05-04:00August 24, 2021|Best Practices, EAR, EEI, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)|Comments Off on Understanding the GOV Export License Exception
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Understanding the Computer Export License Exception (APP)

Background on Export Administration Regulations

 Over 95% of the world’s consumers are outside of the United States. Opportunities abound for U.S. companies that export. However, exporting is a privilege and not a right. U.S. exporters have an important responsibility to adhere to U.S. export control laws, including the Export Administration Regulations (“EAR”).

Administered by the U.S. Commerce Department, the EAR is a set of regulations which governs whether U.S. persons may export or transfer goods, software, and technology outside of the United States or to non-U.S. citizens. U.S. exporters have an important responsibility to adhere to the EAR. Violations of the EAR carry hefty civil and criminal penalties. Exporters can pay hundreds of thousands of dollars in penalties, lose export privileges, and even be imprisoned.

[…]

By |2021-10-07T14:47:23-04:00August 3, 2021|EAR, EEI, Export, Supply Chain, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)|1 Comment
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Understanding Strategic Trade Authorization

Background on Export Administration Regulations

Over 95% of the world’s consumers are outside of the United States. Opportunities abound for U.S. companies that export. However, exporting is a privilege and not a right. U.S. exporters have an important responsibility to adhere to U.S. export control laws, including the Export Administration Regulations (“EAR”).

Administered by the U.S. Commerce Department, the EAR is a set of regulations which governs whether U.S. persons may export or transfer goods, software, and technology outside of the United States or to non-U.S. citizens. U.S. exporters have an important responsibility to adhere to the EAR. Violations of the EAR carry hefty civil and criminal penalties. Exporters can pay hundreds of thousands of dollars in penalties, lose export privileges, and even be imprisoned.

[…]

By |2021-10-07T15:03:47-04:00April 20, 2021|Best Practices, China, EAR, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)|Comments Off on Understanding Strategic Trade Authorization
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New Export Enforcement Priorities Come with New Names at the Bureau of Industry and Security

On April 14, 2011, in Washington, D.C., David Mills, the new Assistant Secretary for Export Enforcement, Bureau of Industry and Security (BIS), U.S. Department of Commerce, and his Special Advisor, Bob Rarog, explained the enforcement priorities of BIS, as established by Eric Hirshorn, who was just sworn in as Under Secretary of the U.S. Commerce Department's Bureau of Industry and Security (BIS) on April 2, 2010, after being appointed by Presdent Obama. This event was part of the American Bar Association's Section of International Law's Export Controls and Economic Sanctions Committee.

By |2011-04-17T13:27:11-04:00April 17, 2011|Export|Comments Off on New Export Enforcement Priorities Come with New Names at the Bureau of Industry and Security
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Save Money by Admitting Your Export Violations to the U.S. Commerce Department

Sometimes it is beneficial for an exporter to voluntarily self-disclose its export violations to the U.S. Government. Maybe an exportation of an item occurred without first obtaining the necessary license, or maybe the items was shipped to a company overseas other than allowed in a license. Both situations are violations of the Export Administration Regulations, and both violations could result in $250,000 penalites against the exporter. By voluntarily sefl-disclosing the violation, the exporter would reduce, and might even eliminate, such a penalty.

By |2010-12-12T21:06:21-05:00December 12, 2010|Export, U.S. Bureau of Industry and Security (BIS)|Comments Off on Save Money by Admitting Your Export Violations to the U.S. Commerce Department
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Everything You Need to Know About Exporting

In the next few weeks, I am giving lectures and doing a webinar on the general topic of export compliance. In my legal practice over the past 20 years as a Customs and International Trade attorney, I am increasingly involved with clients on export compliance and penalty matters, especially with the BIS and OFAC. The laws and regulations have changed dramatically over the past few years, as has the name and number of Federal agencies enforcing them, plus the penalties for non-compliance are much higher now.

By |2009-11-16T11:16:52-05:00November 16, 2009|Export, U.S. Bureau of Industry and Security (BIS), U.S. Office of Foreign Assets Control (OFAC)|Comments Off on Everything You Need to Know About Exporting
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