To Russia, Without License?

There has never been a time in recent memory where export controls and sanctions have played such a role in the geopolitical landscape. The day's leading stories will often have an international trade angle, and the Russian invasion of Ukraine is no exception. Whether it is a Western-origin technology or commodity found on the battlefield, a release of customs documents indicating sanctions-busting imports to Russia, or the arrest of a diverter by Export Enforcement, it all seems to be a compliance officer's worst nightmare. American companies with a good compliance plan are not immune from bad actors: even the government can be fooled by a well-constructed front company. So, what should you do if your gear ends up somewhere it shouldn't be?