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December was a busy month! A highly complex Russian procurement network dismembered, a former Marine indicted, a government contractor sentenced to prison for export violations, and temporary denial orders (TDOs) galore! Let’s get into it.

Overview

  • December saw a flurry of Russia-specific enforcement actions. The Department of Justice (DOJ) indicted a sanctions evader using new criminal forfeiture powers for the first time and interrupted a sophisticated Russian procurement network that had been violating numerous export regulations. Additionally, the Department of Commerce’s Bureau of Industry and Security (BIS) renewed several TDOs against Russian and Belarusian airlines.
  • DOJ took action against a former Marine who violated the International Traffic in Arms Regulations (ITAR) when he provided training to Chinese military pilots. BIS also renewed a TDO on Quicksilver Manufacturing, Inc., Rapid Cut LLC, and US Prototype, Inc. based on evidence that the companies were continuing to send unauthorized exports to China.
  • The Department of Treasury’s Office of Foreign Assets Control (OFAC) settled with Danish manufacturer Danfoss A/S for violating U.S. sanctions on Iran, Sudan, and Syria.
  • Another government contractor was in the news. A Massachusetts man was sentenced to prison following the illegal export of defense technical information to Turkey.
  • The DOJ and the Securities & Exchange Commission (SEC) announced several significant settlements involving matters under the Foreign Corrupt Practices Act.

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Photo of Thad McBride Thad McBride

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP)…

Thad McBride advises public and private companies on the legal considerations essential to successful business operations in a global marketplace. He focuses his practice on counseling clients on compliance with U.S. export regulations (ITAR and EAR), economic sanctions and embargoes, import controls (CBP), and the Foreign Corrupt Practices Act (FCPA). He also advises clients on anti-boycott controls, and assists companies with matters involving the Committee on Foreign Investment in the United States (CFIUS). Thad supports international companies across a range of industries, including aviation, automotive, defense, energy, financial services, manufacturing, medical devices, oilfield services, professional services, research and development, retail, and technology. Beyond advising on day-to-day compliance matters, Thad regularly assists clients in investigations and enforcement actions brought by government agencies, including the U.S. Department of Justice (DOJ), the U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department Directorate of Defense Trade Controls (DDTC), Customs and Border Protection (CBP), the U.S. Commerce Department Bureau of Industry & Security (BIS), and the Securities & Exchange Commission.