International Compliance Digest – August 2024

August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate whistleblowing that will undoubtedly lead to more penalty actions. OFAC issued a new slate of sanctions targeting Russia's supply chains, covering companies both in and outside of Russia. And DHS continued its expansion of the UFLPA list with five new Chinese entities.

August also saw some eye-popping penalties for compliance violations. One company entered into a $200 million settlement agreement with the State Department over violations of the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR). Another enforcement action from CFIUS resulted in a $60 million penalty – its largest penalty to date. Commerce's BIS imposed a $5.8 million penalty for export control violations.