The Securities and Exchange Commission announced that Moog Inc., a New York-based global manufacturer of motion controls systems for aerospace, defense, industrial and medical markets, agreed to pay a civil penalty of $1.1 million to resolve the SEC’s charges that it violated the Foreign Corrupt Practices Act (FCPA) arising out of bribes paid by its wholly owned Indian subsidiary, Moog Motion Controls Private Limited .

The White House is considering various import prohibition options on the basis that Chinese nationals are engaging in trade or taking of pangolins that diminishes the effectiveness of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). China remains the largest destination country for pangolin scales

The Securities and Exchange Commission's  2012 conflict minerals disclosure rule has not reduced violence in the Democratic Republic of the Congo (DRC) and has likely had no effect in adjoining countries, according to a GAO report released October 7th. The SEC rule requires companies to file reports on their use of tantalum, tin, tungsten, and gold, which are mined in the DRC. GAO found no empirical evidence that the rule has decreased the occurrence or level of violence in the eastern DRC, where many mines and armed groups are located

Totonto Dominion Bank will pay over $3 billion in fines and is subject to a cap on US growth after regulators uncovered widespread money laundering failures in the banks Philadelphia and Miami operations. Prosecutors said the bank operated with inadequate guards against money laundering for nearly a decade, failing to act even when staff flagged obvious cases of abuse, such as a customer making daily deposits of $1m in cash.

Two Russian nationals were charged Thursday for export control violations, smuggling, wire fraud, and money laundering in connection with a scheme to procure U.S.-sourced microelectronics subject to U.S. export controls on behalf of a Russia-based supplier of critical electronics components for manufacturers supplying weaponry and other equipment to the Russian military.

The UK's Office of Trade Sanctions Implementation (OTSI), within the Department for Business and Trade, opened last week. This new sanctions body has been established to strengthen the enforcement of trade sanctions and support businesses with compliance.. Complementing HMRC’s trade sanctions enforcement role at the UK border, OTSI has new civil enforcement powers in relation to services as well as movement of goods across third country borders, where there is a UK nexus.

On September 23, the Inspector General's Office of the Department of Commerce released its audit of the Bureau of Industry and Security’s (BIS’) efforts to "counter China’s Military-Civilian Fusion strategy"   The auditors found the BIS export license approval process "adequate in reducing the risk" of controlled items being inappropriately approved for export to China. However, they found that BIS has "not minimized the risk of unauthorized release of controlled technologies and software to China."

Previously under sanctions due to its ties to Imperial Yachts, the 136 meter (446 ft) superyacht Flying Fox is likely to be free to operate globally without restrictions. …

The Commerce Department's Bureau of Industry and Security (BIS) published guidance for financial institutions containing best practice recommendations for complying with the Export Administration Regulations (EAR).  The guidance focuses on General Prohibition 10 (GP 10), which prohibits financial institutions (and other persons) from financing or otherwise servicing any item subject to the EAR with knowledge that a violation of EAR has occurred, is about to occur, or is intended to occur.

Precision Castparts Corp. settled allegations that it violated the International Traffic in Arms Regulations (ITAR) in connection with unauthorized exports of technical data to foreign-person employees from Bhutan, Burundi, El Salvador, Honduras, Mexico, and Peru pertaining to tools (specifically, wax pattern and core dies) and wax patterns consumed in the subsequent production of casting blades used in gas turbine engines

From October, the Office of Trade Sanctions Implementation (OTSI) will be empowered to investigate breaches of trade sanctions and impose corresponding civil monetary penalties. We examine the powers OTSI will have, how it will interact with other UK sanctions authorities and what impact it may have.

OFAC is amending the Reporting, Procedures and Penalties Regulations (RPPR). the May 2024 Interim Final Rule requiring reports witin 10 business days of when blocked property is unblocked or transferred, This final rule adds three exceptions to the reporting requirement for any blocked property that is unblocked or transferred.

The Justice Department announced the unsealing of a warrant authorizing the seizure of 41 internet domains used by Russian intelligence agents and their proxies to commit computer fraud and abuse in the United States. As an example of public-private operational collaboration the Department acted concurrently with a Microsoft civil action to restrain 66 internet domains used by the same actors

After a particularly slow second quarter, FCPA enforcement activity picked up between July and September of 2024, with the DOJ initiating one new FCPA-related enforcement action, unsealing two previously filed actions, and issuing one declination letter, according to a tally from Stanford University's FCPA Clearinghouse. "Enforcement activity through Q3 of this year remained well below even the last three years of lower than average enforcement" the report notes

The Board of Directors at the Export-Import Bank of the United States (EXIM) last week voted to approve a Non-Binding Resolution in Support of Critical Minerals and Rare Earths Financings to reaffirm its support for critical minerals transactions. The resolution amplifies EXIM’s current efforts to utilize its lending and underwriting tools to support critical minerals and rare earths projects. 

For the first time,  steel and artificial sweetener companies have been added to the UFLPA Entity List.  Customs and Border Protection (CBP) will apply a rebuttable presumption that goods produced by Baowu Group Xinjiang Bayi Iron and Steel Co., Ltd. and Changzhou Guanghui Food Ingredients Co., Ltd.

Before the Commerce Department's U.S. Commercial Service can provide export-related services to clients, such as assistance with identifying potential partners or providing due diligence, specific information is required to determine the client’s business objectives and needs. Public comments were previously requested via the Federal Register on July 29, 2024, during a 60-day comment period. This notice allows for an additional 30 days for public comments.

Determinedly beating the drum for steelworker votes and economic populism, two of the leading Senate opponents of the purchase of US Steel by a Japanese rival drew attention to the executive compensation of the Pittsburgh steelmaker. Elizabeth Warren (D-Mass) sent a letter to US Steel CEO David Burritt outlining their concerns. with plans for the firm's current and former top executives to receive payments totaling over $156 million – not including $40.8 million in payments to non-employee board members.

Developing and developed members applauded the EU decision to postpone the implementation of its new Regulation on Deforestation-Free Products (EUDR) for twelve months.   This regulation, which was set to take effect on 30 December 2024, will require a variety of agricultural products sold in the EU market to be "deforestation-free," meaning they must not result from recent (post-31 December 2020) deforestation, forest degradation, or breaches of local environmental and social laws.

The Financial Crimes Enforcement Network (FinCEN) has updated some of its Beneficial Ownership Information Frequently Asked Questions and issued several additional ones. The topics covered are: …