Company Incurs $6 Million Penalty for Export of Controlled Software and Technical Data

21 September 2021 – A recent export enforcement case describes a common compliance challenge faced by many U.S. companies. In this case,[1] a California company manufactured electronic test and measurement equipment for both commercial and government customers. The company failed to identify that one of its software products was listed on the U.S. Munitions List and…

The SAP Enforcement Action: The Need for Robust and Timely Post-Acquisition Integration

13 May 2021 – The SAP enforcement action was certainly a game-changer in trade sanction enforcement. It was the first Justice Department (DOJ) National Security Section enforcement action under the under the Justice Department’s Export Control and Sanctions Enforcement Policy. Mike Volkov, channeling his inner Grace Slick, called it “a New Dawn”. Moreover, although the enforcement…