Category: Enforcement

ITAR Control of Public Speech

The State Department released a Federal Register notice today proposing to amend definitions for “public domain,” “fundamental research,” “defense services,” and “technical data” under the International Traffic in Arms Regulations (“ITAR”). [F/N 1] Among other things, the notice explicitly confirms that the State Department imposes a prepublication approval requirement […]

Who You Gonna Call?

Your company may be able to gain a legitimate competitive advantage by reporting a competitor’s export control violations. But which agency should you call to turn in the competition? Suspected export control violations are most commonly investigated by special agents of the Federal Bureau of Investigation National Security […]

Proposed Changes to Unverified List

On September 11, 2013, the Department of Commerce Bureau of Industry and Security (“BIS”) issued a proposed notice of rulemaking to amend various provisions of the EAR governing transactions with parties identified on the Unverified List (“UVL”).[1]

Prosecution of Individuals for Violations

The Department of Justice has always pursued individuals for export control violations.  However, the administering agencies have historically been less aggressive in referring cases that involve violations by employees making exports on behalf of their employers.  In these cases, agencies typically sanctioned the employer for the employee actions […]