Matthew S. Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce, released a memorandum July 26, 2023, announcing changes in antiboycott reporting and compliance requirements. This announcement follows a series of similar memorandums from the Department of Commerce that have increased the intensity of export enforcement actions. History of U.S. Antiboycott Regulations … Read more
A Five Eyes export control agreement seeks to enhance the security concerns of Australia, Canada, New Zealand, the United Kingdom, and the United States by formally committing to coordinate export control enforcement efforts. Matthew S. Axelrod, Assistant Secretary of Commerce for Export Enforcement, stated that this will result in detentions, public identification, and penalties for … Read more
The Department of Defense (DoD) is addressing foreign influence in academia with the publication a foreign entities list that includes threats to U.S. national security. This was announced in an address from Heidi Shyu, Under Secretary of Defense for Research and Engineering (USD R&E). By adding this requirement for screening of potential partners, the Pentagon … Read more
During a recent address at the Ethics and Compliance Initiative Impact Conference, Marshall Miller, the Principal Associate Deputy Attorney General at the Department of Justice (DOJ), stressed Export Compliance diligence in ensuring compliance with export regulations. He further stated that as the agency continues enforcement efforts connected to United States national security investigations that they … Read more
Recent enforcement activities by the Bureau of Industry and Security (BIS) illustrate the importance of having a viable Export Administration Regulations (EAR) Export Compliance Program. These events including a 300-million-dollar penalty imposed on Seagate Technology earlier this year, are as Assistant Secretary for Export Enforcement Matthew Axelrod described, “a clarion call” for businesses to comply … Read more
BIS restrictions on technologies to the PRC are being put in place to limit China’s ability to enhance its military capabilities, according to Thea D. Roxman Kendler in testimony to the Senate Banking, Housing, and Urban Affairs Committee. Roxman is the Assistant Secretary of Commerce at the Bureau of Industry and Security (BIS) in charge … Read more
The #Stopransomware Guide update was released in May 2023 jointly by the Cybersecurity and Infrastructure Security Agency (CISA) and the Multi-State Information Sharing & Analysis Center (MS-ISAC). Information in this guide was developed by the Joint Ransomware Task Force (JRTF) which is overseen by the Federal Bureau of Investigation (FBI) and CISA. to help organizations … Read more
The government of Canada has specific Controlled Goods Program (CGP) Cloud Solutions requirements for individuals or organizations that possess or transfer controlled goods and associated technical data. Technical data includes drawings, blueprints, software, or technical documentation that could be used or adapted for military or space end use. Cloud service providers that provide storage or … Read more
Canadian Controlled Goods Program (CGP) security plans are a requirement for work sites where goods are examined, possessed, or transferred. This is a requirement for all companies registered in the CGP as described in section 10 of the Controlled Goods Regulations. Controlled goods are primarily items, components and technical data that have been designated as … Read more
A 300-million-dollar penalty was imposed on Seagate Technology, LCC, by the Bureau of Industry and Security (BIS). These administrative penalties were leveled at the business’s operations in Fremont, California and Singapore and include a five-year suspended Denial Order, which if activated, would terminate the organization’s ability to conduct export business under the Export Administration Regulations … Read more
The Bureau of Industry and Security (BIS) addressed human rights abuses with additions to the Entity List of individuals and organizations that are enabling or engaging in human rights violations. The eleven entities added, in March of 2023, are based in China, Burma, Russia, and Nicaragua. These actions demonstrate the ongoing efforts by the Department … Read more
Microsoft export violations have resulted in multi-million-dollar penalties for the software provider. The company has made voluntary disclosures to the Bureau of Industry and Security (BIS), the Department of the Treasury’s Office of Foreign Assets Controls (OFAC), and the Department of Justice (DOJ). Most of these reported violations occurred between 2012 and 2019. These violations … Read more
As 2023 opens it appears that there may be further delays in CMMC 2.0 reaching a final ruling as the Pentagon considers additional revisions of the proposed rule. These reconsiderations are, as reported on ClearanceJobs, the result of internal politics and concerns on the impact on businesses. Because the rule is in proposed status, it … Read more
The Directorate of Defense Trade Control (DDTC) has released Export Compliance Program Guidelines to provide businesses with an overview of best practices for complying with the International Traffic in Arms Regulations (ITAR). These guidelines encourage organizations to adopt robust policies and procedures to ensure that compliance with export controls for items enumerated in the United … Read more
Life Cycle Environmental Profile MIL-STD-810 Tailoring is Essential for Valid Testing The United States Department of Defense (DoD) has stressed the importance of MIL-STD-810 tailoring since its inception. This essential task has been outlined in Part 1 of the specification since revision F in 2000. Since this time Part 1 has been modified to provide … Read more
ITAR, EAR, and CGP Having an Export Compliance Program is a Requirement It is a requirement for businesses conducting exports of controlled products and services in the U.S, and Canada to implement and maintain an export compliance program. These programs are required to protect the national security and foreign policies of the respective nations. Failure … Read more
