Enforcement

The Treasury Department announced sanctions targeting individuals and entities tied to oil smuggling and narcotics trafficking networks linked to the Jalisco New Generation Cartel (CJNG). The action aligns with the Administration’s focus on southwest border enforcement and the financial disruption of designated Foreign Terrorist Organizations. The Office of Foreign Assets Control (OFAC) designated three Mexican nationals and two Mexico-based companies for their roles in smuggling crude oil stolen from Petróleos Mexicanos (Pemex) into the United States. 

David Peters has been nominated to be Assistant Secretary of Commerce for Export Enforcement, plugging one of the largest remaining gaps in the org chart at the Bureau of Industry and Security. Peters, most recently a Trial Attorney in the Fraud Section, Market Integrity and Major Frauds of the Justice Department takes the reins from Matt Axelrod, now with Gibson Dunn in Washington.

The Justice Department announced that it has declined the prosecution of Universities Space Research Association (USRA) after it self-disclosed five years ago criminal violations of U.S. export control laws committed by its former employee. Jonathan Soong pleaded guilty in January 2023 to willfully violating the Export Administration Regulations (EAR) by exporting U.S. Army-developed aviation software to a university in the People’s Republic of China (PRC) that had been placed on the Commerce Department’s Entity List and was sentenced to 20 months in prison.

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule in the Federal Register amending the Export Administration Regulations (EAR) to add 18 foreign entities to the Unverified List (UVL) and remove five previously listed parties.

The U.K. Serious Fraud Office (SFO) has charged United Insurance Brokers Limited (UIBL) with failing to prevent bribery by its associates in a case involving multimillion-dollar reinsurance contracts in Ecuador. UIBL, a London-based reinsurance firm, is accused of allowing U.S.-based intermediaries to bribe Ecuadorean officials between October 2013 and March 2016 in exchange for awarding contracts valued at approximately $38 million. The contracts were issued by state-owned insurers covering Ecuador’s public sector infrastructure, including water and electricity companies.

Taiwan Semiconductor Manufacturing Company (TSMC) is under investigation by the U.S. Department of Commerce for potential violations of export control regulations, a case which may give Commerce Secretary Howard Lutnick and BIS Chief Jeffrey Kessler an opportunity to impose their promised "dramatic increase in enforcement and fines for people who break the rules.

The Bureau of Industry and Security (BIS) has published an updated Antiboycott Requester List, identifying foreign companies that have issued boycott-related requests in contravention of U.S. regulations. The update adds 30 new parties and removes 18 entities that certified they no longer include boycott-related terms in transactions involving U.S. persons.

Perkins Coie has launched a dedicated website, perkinscoiefacts.com, outlining their response to the unconstitutional Executive Order targeting the firm.  The site houses statements, filings, and other information about their response to the Order.

A  Russian national residing in Florida was sentenced to 70 months in prison for conspiring to illegally export controlled aviation technology to Russia and for laundering funds connected to the scheme. His co-conspirator was sentenced in December 2024 to two years in prison.

In separate prosecutions under the Lacey Act, the U.S. Department of Justice announced the sentencing of five individuals for wildlife trafficking operations that illegally exported protected species from U.S. territories to Asia and the Caribbean.

A federal indictment unsealed March 27 charges a dual Pakistan-Canada citizen for running a procurement scheme to acquire U.S.-origin goods and technologies on behalf of Pakistani entities linked to the country’s nuclear, missile, and unmanned aerial vehicle (UAV) programs.

The U.S. Department of Justice has terminated early two corporate monitorships imposed on Glencore plc as part of the mining giant’s 2022 settlement over foreign bribery and market manipulation, following an executive directive by President Donald J. Trump halting enforcement of the Foreign Corrupt Practices Act (FCPA).

The United States has filed a civil forfeiture complaint in the Southern District of Florida against a Dassault Falcon 900 EX aircraft, tail number T7-ESPRT, used by Nicolás Maduro Moros and his regime in violation of U.S. sanctions and export laws. The aircraft was seized last year in the Dominican Republic at the request of the U.S.

In a sweeping overhaul of the Justice Department’s senior leadership, the White House has removed or reassigned dozens of career officials, particularly within the National Security Division (NSD), signaling a dramatic shift in the department’s priorities and approach to the rule of law. The moves reflect the President’s unconventional approach to governance, marked by a disregard for institutional norms and an emphasis on loyalty over established legal expertise.

Despite the Justice Department's dismantling of inter-agency cooperation to enforce sanctions and combat corruption, cases begun before the change of regime continue to wend their way though the courts. March 10, The U.S. District Court for the Southern District of New York granted the government’s motion to strike the ownership claim of Eduard Khudainatov and Millemarin Investments Ltd. concerning the Motor Yacht Amadea.

The White House having declared a policy of indifference to foreign corrupt practices, Justice officials abruptly scrubbed plans to participate in the American Bar Association's annual Conference on White Collar Crime in Miami. In a related development, two former Cognizant Technology Solutions executives charged over an alleged foreign bribery scheme may get a reprieve, as the newly installed US attorney for New Jersey, John Giordano asked the judge for a six-month extension “to allow sufficient time for my consideration” of  the Executive Order.    Two weeks earlier, the US Attorney’s office had indicated to the court that it was prepared to proceed with the trial.

The growing number of aerospace smuggling cases reflects a broad and deep crisis within Russia's civilian airline industry, which has been under sweeping US and European sanctions since Moscow launched its full-scale invasion of Ukraine in February 2022. RFE/RL Correspondent Todd Prince reports on the efforts of Russian airlines to stretch aircraft lifespans by smuggling certified parts from the United States and Europe unofficial sources, resorting to unofficial maintenance checks and reducing flight frequency.

The owner of a Raleigh, North Carolina electronics resale business, pleaded guilty to attempting to export accelerometer technology with military applications to China without a license.  According to court documents, David Bohmerwald purchased 100 accelerometers from a U.S.-based electronics company, intending to export them to a Chinese business. Authorities were alerted when the U.S. electronics company found Bohmerwald’s purchase suspicious.

California man Liming Li pleaded guilty today in the United States District Court for the Central District of California to one count of possession of trade secrets. Li admitted to unlawfully retaining proprietary information from his former Southern California-based employers and using it to market his own competing company to a China-based entity. Li was arrested on May 6, 2023, at Ontario International Airport upon returning from Taiwan. A subsequent FBI search of his residence revealed numerous digital devices containing proprietary files belonging to his former employers.

Alabama man Ray Hunt, has been sentenced to five years in prison for violating the International Emergency Economic Powers Act. In July 2024, Hunt pleaded guilty to conspiring to export U.S.-origin goods to the Islamic Republic of Iran in violation of the U.S. trade sanctions. Beginning at least as early as 2015 and continuing to the time of his arrest in November 2022, Hunt conspired with two Iranian companies located in Tehran, Iran, to illegally export U.S.-manufactured industrial equipment for use in Iran’s oil, gas, and petrochemical industries.

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