A New Era Of Export Control And Sanctions Enforcement

Since the Russian invasion of Ukraine in February 2022, the U.S. government has made it increasingly clear that enforcement of export control and economic sanctions laws is a top priority. From launching task forces to target illicit actors, to engaging in closer cooperation with authorities in Canada, the United Kingdom, and the European Union on global investigations and enforcement efforts, the Commerce Department's Bureau of Industry and Security (BIS), the Treasury Department's Office of Foreign Assets Control (OFAC), and the Department of Justice (DOJ) are aggressively enforcing these laws and regulations.

Recently, BIS upped the ante, announcing several significant enforcement policy changes that aim to impose higher penalties on companies that have engaged in significant violations of export control requirements, including penalizing those that decide not to voluntarily disclose such violations. At the same time, both BIS and Congress have incentivized