- Key takeaway #1 Companies should be mindful that the U.S. agencies responsible for civil and criminal export controls and sanctions compliance maintain separate VSD policies. This announcement highlights key aspects of each VSD policy.
- Key takeaway #2 Failure to initiate an internal investigation promptly after discovering a potential export controls or sanctions
Five Eyes Partners Reach Agreement on Export Control Enforcement Cooperation
On June 28, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security issued a press release reporting formal cooperation amongst the Five Eyes Intelligence Oversight and Review Council (“Five Eyes”) to expand enforcement of export controls. Five Eyes—an intelligence alliance between Australia, Canada, New Zealand, the United Kingdom, and United States—formalized its cooperation…
Sanctions/Export Highlights [As of June 30, 2022]
Russia Sanctions: This week the United States designated dozens of additional entities and individuals as Specially Designated Nationals (“SDNs”). Notable designations included State Corporation Rostec (“Rostec”), a large Russian state-owned company that operates in the automotive, defense, aviation, and metal industries; individuals who were part of a covert procurement network linked to Russia’s Federal…