International Trade, Enforcement & Compliance Recent Developments Update (January 3, 2024)

Welcome to Foley's International Trade, Enforcement & Compliance Recent Developments Update.

Perhaps jealous of all the attention that these Recent Development updates have given to import matters, the Departments of Commerce and State remind us that export controls enforcement also is a big priority for the U.S. government. Throw in an economic sanctions enforcement action and we have a timely reminder that it's never a bad idea to check on the efficacy of your export controls and economic sanctions screening and other export-related compliance measures.

Export Controls Enforcement

The Department of Commerce has adopted a new policy that failure to disclose a known export controls violation constitutes a significant aggravating factor, while also clarifying that turning in another company will be treated as a significant mitigating factor, even for an unrelated violation that occurs later in time. Does your company maintain strong export control and economic