District Court Throws Out OFAC Penalty, Citing Due Process, Unclear Regulations

Enforcement, OFAC, Sanctions, Ukraine, Violations & Fines

By Nicholas Turner, Meredith Rathbone, Brian Egan and Ed Krauland (Steptoe & Johnson LLP) On December 31, 2019, the U.S. District Court for the Northern District of Texas threw out a $2 million fine issued in 2017 by the Treasury Department’s Office of Foreign...

Justice Department Publishes Enforcement Policy for Export Controls and Sanctions

DOJ, Enforcement, Violations & Fines, Voluntary Disclosure

By: Danielle Hatch In December 2019 the Department of Justice (DOJ) released a policy, through the National Security Division’s (NSD) Counterintelligence and Export Control Section (CES) that sets forth the criteria that will be used in determining solutions for...

Indonesian Man and Three Companies Charged with Violating Iran Sanctions

Commerce Dept, Denied & Restricted Parties, Enforcement, Indonesia, Iran, OFAC, Sanctions, Violations & Fines

By: Danielle Hatch Sunarko Kuntjoro, a citizen of Indonesia, and three Indonesian-based companies have been charged with violating US export laws related to the US sanctions against Iran. PT MS Aero Support (PTMS), PT Kandiyasa Energi Utama (PTKEU), and PT Antasena...

US Navy Contractor Fined $84K for Providing Technical Drawings to China

BIS, Canada, China, Denied & Restricted Parties, Enforcement, Violations & Fines

By: Danielle Hatch Former US Navy contractor, OceanWorks International Cooperation (OceanWorks) and it’s president, Glen Omer Viau were involved in a scheme where they provided US Navy technical data to a company in China that was working on the design and...

Apple Fined $466,912 for Screening Failure

BIS, Denied & Restricted Parties, Enforcement, OFAC, Sanctions, Violations & Fines

By: Danielle Hatch Apple, Inc. voluntarily disclosed to the Office of Foreign Assets Control (OFAC) its violations related to the Foreign Narcotics Kingpin Sanctions Regulations (FNKSR). In 2008 Apple entered into an app development agreement with SIS, d.o.o. (SIS), a...

D.C. Circuit Weighs in on Issue of Willfulness in Prosecutions for Unlawful Exports

Enforcement, ITAR, USA Regulations

Source: Torres Law (http://www.torrestradelaw.com/posts/D.C.-Circuit-Weighs-in-on-Issue-of-Willfulness-in-Prosecutions-for-Unlawful-Exports/184) What is the appropriate standard for determining whether a defendant has acted willfully in violation of the Arms Export...