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April 20, 2020

OFAC to consider COVID-19 issues when addressing “apparent violations” of its regulations

The Office of Foreign Assets Control, often one of the most difficult and implacable federal agencies to deal with, has announced its intent to consider COVID-19 issues when addressing “apparent violations” of its regulations.   In a release dated April 20, 2020, it stated “If a business facing technical and resource challenges caused by the COVID-19 pandemic chooses, as part […]

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March 4, 2019

Have A Billion Dollar Export Penalty? Let’s Not.

         This is an old blog we lost during our transfer of site hosting.      A record-setting payment of $1,190,000,000.00 by ZTE Corporation of Richardson, Texas (“ZTE”) shows the enormous risks today of underestimating U.S. export enforcement. The International Emergency Economic Powers Act gives the President of the United States broad authority to regulate international transactions and exports.. Pursuant […]

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