Practices. Export Controls & Economic Sanctions. PRIMARY CONTACTS Steven Brotherton

Transcription

1 Practices PRIMARY CONTACTS Steven Brotherton PROFESSIONALS Jared Hollett Nina Mohseni Jenna Glass Export Controls & Economic Sanctions Sandler, Travis & Rosenberg offers a complete range of services relating to export controls and economic sanctions, including those of the United States, Latin America, the European Union, and Asia. We counsel companies and academic institutions on all aspects of export controls and sanctions, including, in the United States, the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the sanctions regulations maintained by the Treasury Department s Office of Foreign Assets Control (OFAC). We also provide guidance on international export control regulations. We are involved in a broad range of export control activities and our achievements have included the following. provided export control-related counseling and advice to over half of the Fortune 50 companies performed State Department-mandated ITAR audit of $20 billion electronics company, reviewing over 25 key manufacturing locations in five countries assisted a variety of start-ups with export control program needs, providing day-to-day counseling and export classification support as the companies grew served as outsourced export compliance management for a variety of clients, performing export licensing, classification and compliance program development and implementation served as lead counsel for the successful resolution of a major ITAR jurisdiction dispute impacting the global aircraft and automobile industries conducted internal investigation and assisted in preparation of voluntary disclosure involving more than 1,000 violations of the ITAR, resulting in the issuance of a warning letter in lieu of fines and penalties prepared voluntary disclosures for numerous companies and academic institutions regarding the unlawful transfer of controlled technology to foreign nationals ( deemed exports ). led self-classification efforts for major semiconductor, electronics and telecommunications companies covering thousands of commodities and technologies, including the development of comprehensive ECCN

2 matrices represented a major research university in obtaining a landmark advisory opinion from the U.S. Department of State on the application of the fundamental research exemption in an academic setting developed a de minimis evaluation tool and assisted leading foreign companies in de minimis and foreign direct product rule evaluations prepared export compliance programs and website materials for a variety of universities News Alerts & Advisories Exports to Major Chinese Telecom Company Banned (April 16, 2018) Increasing Demand Prompts Expansion of Sandler, Travis & Rosenberg Export Controls and Sanctions Practice (December 12, 2017) New Requirements on Exports To, Through Hong Kong Could Pose Challenges (January 26, 2017) Export Controls Expert Steven Brotherton Joins Sandler, Travis & Rosenberg as Practice Group Leader (October 17, 2016) BIS Proposes Tougher Requirements for Exports to Entities on Unverified List (September 12, 2013) STR STTAS Advisory Publications Nonproliferation Measures Imposed for Shipments to Iran, North Korea, and Syria (May 10, 2018) Chinese Company Requests Suspension of Export Ban (May 9, 2018) Nonproliferation Measures Imposed on Russian Defense Export Agency (May 9, 2018) Iran Sanctions Affecting Foreign Subsidiaries, Financial Transactions to be Reinstated (May 9, 2018) $100,000 Penalty for Conspiracy to Export Controlled Items to China (April 30, 2018) Export Violations Net Defense Trade Ban for 168 Individuals (April 25, 2018) Electronic Disclosure of Arms Export Violation Under Development (April 18, 2018) Export Privileges Suspended for Unlicensed Shipments (April 12, 2018) Sanctions on Russian Entities Expanded (April 9, 2018) Export Controls on Chemicals and Biological Agents Updated (April 4, 2018) Export Regulations and Procedures Committee to Meet (March 30, 2018)

3 Prison Sentence for Facilitating Illegal Exports to Iran (March 23, 2018) Restrictions on Exports of EAR-Regulated Goods Added, Revised, Removed (March 22, 2018) Export Privileges Suspended for Unlicensed Shipments of Defense Items (March 22, 2018) Unrepentant Exporter Gets Tougher Penalty for Violative Shipments (March 5, 2018) North Korea Sanctions Regulations Updated, Reissued (March 2, 2018) More Foreign Entities, Shipping Companies Hit with North Korea-Related Sanctions (February 27, 2018) Company Penalized for Anti-Boycott Violations (February 26, 2018) Export Committees to Discuss Regulatory Changes, Other Issues (February 19, 2018) Exports of EAR-Regulated Goods Restricted to 21 Entities (February 16, 2018) Defense Trade Regulations Amended to Reflect South Sudan Ban, Exceptions (February 15, 2018) Export Privileges Suspended for Unlicensed Shipments (February 14, 2018) Export Controls on Explosives, Protective Gear, Military Electronics Under Review (February 12, 2018) Export Enforcement Chief Named (February 9, 2018) U.S. Bans Arms Exports to South Sudan (February 6, 2018) Sanctions on Russian and Ukrainian Entities Expanded (February 5, 2018) Nonproliferation Measures Imposed on North Korean Entities (February 1, 2018) Chinese Entities, North Korean Shipping Companies Among Targets of New U.S. Sanctions (January 29, 2018) Restrictions on Exports of EAR-Regulated Goods Added, Revised, Removed (January 29, 2018) Export Violation Nets Fine, Prison Sentence (January 26, 2018) Export Committee on Sensors and Instrumentation to Meet (January 22, 2018) Trump Threatens to Reinstate Iran Sanctions Affecting Non-U.S. Subsidiaries (January 18, 2018) $10,000 Penalty for Unlicensed Exports to China (January 18, 2018) $37,000 Penalty for Anti-Boycott Violations (January 10, 2018) No Changes to International Boycott Country List (January 8, 2018) Export Privileges Suspended for Shipments to Iran (December 27, 2017) Export Privileges Suspended for Unlicensed Shipments (December 26, 2017) Electronic Filing Required for Some EPA-Regulated Exports (December 26, 2017)

4 Prison Sentences, Fines for Export of Prohibited Articles to Syria (December 22, 2017) Exports of EAR-Regulated Goods Restricted to Two Russian Entities (December 20, 2017) $1.22 Million Penalty for Transshipment of Goods to Iran (December 11, 2017) OFAC Declines to Issue Penalty for Iran Sanctions Violation (December 1, 2017) Export Regulations Advisory Committee to Meet Dec. 12 (December 1, 2017) Bank Penalized for Anti-Boycott Violations (November 30, 2017) Additional North Korea Sanctions Announced (November 27, 2017) OFAC Removes Côte d Ivoire Sanctions Regulations (November 10, 2017) Export Restrictions Among Cuba Policy Changes (November 9, 2017) OFAC Implements Expansion of Prohibition on Doing Business With Russian Entities (November 3, 2017) Terrorism Sanctions Regulations Updated (October 31, 2017) Export Privileges Suspended for Unlicensed Shipments (October 20, 2017) Export Controls on Information Systems to be Discussed at BIS Meeting (October 18, 2017) $250,000 Penalty, Suspension of Export Privileges for Violation of Temporary Denial Order (October 12, 2017) Facilitating Third-Country Export to Sudan Nets OFAC Penalty (October 11, 2017) Economic Sanctions Against Sudan Largely Revoked (October 10, 2017) $60,000 Penalty for Anti-Boycott Violations (October 6, 2017) $230,000 Penalty for Unlicensed Exports to China and Russia (October 3, 2017) Penalty Case Highlights Risks of Shipping Directly to Foreign Customers, OFAC Says (October 2, 2017) Restrictions on Exports of EAR-Regulated Goods Removed, Revised (September 26, 2017) Hong Kong Rules, Deemed Exports, Licensing Among Recommended Changes for BIS (September 19, 2017) Export Privileges Suspended for Unlicensed Shipments to Russia, Mexico (September 18, 2017) Voluntary Disclosures, Remedial Measures Yield Mitigated Penalty for Unauthorized Exports (September 15, 2017) 57 Month Prison Sentence for Conspiring to Export Specialty Metals to Iran (September 15, 2017) $100,000 Penalty for Conspiracy to Export Item to Iran (September 8, 2017) Prison Sentence for Attempted Export of Restricted Goods to China (September 7, 2017) Foreign Policy-Based Export Controls Subject of Annual BIS Review (September 7, 2017)

5 Civil Penalties for Anti-Boycott Violations (September 4, 2017) Small-Scale Natural Gas Exports Expedited Under DOE Proposal (September 4, 2017) $35,000 Penalty, Compliance Audit for Unlicensed Exports to India (August 31, 2017) Iran Sanctions Violations Net $415,350 Penalty (August 30, 2017) Hazardous Waste Exports Must be Filed in AES as of Dec. 31 (August 30, 2017) $518,000 Penalty for Iran Sanctions Violations (August 24, 2017) Export Regulations Revised to Reflect Changes to Dual-Use Goods List (August 15, 2017) Export Privileges Suspended for Unlicensed Shipments (August 15, 2017) Cooperation, Remedial Actions Offset Ineffective Compliance Program in Iran Sanctions Case (August 14, 2017) U.S. Expands Economic Sanctions Against Russia, Iran, North Korea (August 4, 2017) Defense Export Debarment Rescinded for Canadian Company (August 2, 2017) Prison Term, Civil Penalty for Export Violations (August 1, 2017) Willful Diversion of Defense Exports Evident in Only Small Percentage of Cases, Report Finds (July 24, 2017) $2 Million Penalty for Sanctions Violations Protested as Unfair (July 21, 2017) Prison Sentence for Illegal Exports to Iran (July 19, 2017) Export Control Regulations Amended to Reflect Missile Technology Regime Changes (July 11, 2017) Export Committees on Emerging Technology, Materials, Sensors, Etc. to Meet (July 4, 2017) Export Privileges Suspended for Unlicensed Exports of Defense Articles (July 3, 2017) Civil Penalty Imposed to Settle Charges of Illegal Export to Iran (June 30, 2017) Draft Chinese Export Control Law Would Make Significant Changes (June 29, 2017) Sanctions Violations Net Penalty, Caution to Use Risk Management Tools (June 28, 2017) Restrictions on Exports of EAR-Regulated Goods Added for Russian, Ukrainian Entities (June 23, 2017) Vietnam Plans Import Licensing Requirement for Cyber Information Security Products (June 22, 2017) Penalty, Export Controls Audit Ordered for Unlicensed Export to Russia (June 19, 2017) $700,000 Penalty for Unlicensed Exports (June 16, 2017) Final Rule Revising Export Regulations to Reflect Changes to Dual-Use Goods List Corrected (June 14, 2017) Export Committee to Review Enforcement, Regulations, AES (June 1, 2017)

6 Export Control Reform Initiative Needs Review, Possible Changes, Report Says (May 31, 2017) Restrictions on Exports of EAR-Regulated Goods Added, Revised (May 26, 2017) Export Agency Assistant Chief Named (May 23, 2017) Export Committee on Materials and Related Technology to Meet (April 26, 2017) Export Committees on Materials Processing Equipment, Transportation Equipment to Meet (April 25, 2017) New Requirements for Exports To, Through Hong Kong Further Clarified (April 21, 2017) Information Systems Export Controls Committee to Meet (April 11, 2017) Restrictions on Exports to Russia to be Further Eased (April 11, 2017) Some Export Rules on Hold Due to Regulatory Directives (April 10, 2017) Landmark Penalty Case Has Lessons for Exporters, Official Says (April 6, 2017) Exports Restricted to Six Persons Added to Unverified List (April 6, 2017) BIS Clarifies New Requirements on Exports To, Through Hong Kong (April 4, 2017) Export Agency Chief Named (April 4, 2017) Nonproliferation Measures Imposed for Shipments to Iran, North Korea and Syria (March 31, 2017) Export Control Practice Lead Reappointed to Federal Advisory Committee (March 29, 2017) Restrictions on Exports of EAR-Regulated Goods to Two ZTE Entities Removed (March 29, 2017) Export Privileges Suspended for Illegally Attempting to Export Defense Article (March 17, 2017) Large Penalty Assessed for Widespread EAR Violations (March 16, 2017) Man Faces Substantial Sentence for Illegally Exporting Controlled Technology to Ukraine (March 13, 2017) Export Permit System for Furbearing Animals Proposed for Continuation (March 10, 2017) Largest Ever Civil Penalty for Export Control Violations Assessed on Chinese Company (March 8, 2017) Export Advisory Committees Seek New Members (March 8, 2017) Export Committees on Regulations, Emerging Technology, Sensors to Meet (March 7, 2017) Eleven Individuals, One Company Charged with Exporting Prohibited Articles to Syria (February 28, 2017) Suspension of Restrictions on Exports to Two ZTE Entities Extended (February 24, 2017) Export Committees on Emerging Technology, Materials, Transportation to Meet (February 20, 2017) Export Restrictions Eased on Certain EAR-Controlled Goods (January 23, 2017)

7 Stricter Export Controls for Infrared Detection Items Under Consideration (January 13, 2017) Export Committees on Information Systems, Sensors and Instrumentation to Meet (January 11, 2017) Restrictions on Exports of EAR-Regulated Goods Added, Removed, Revised (January 10, 2017) Export Controls on Spacecraft Systems Revised Again (January 10, 2017) New Restrictions on Exports of EAR-Regulated Goods to Russian Entities (January 4, 2017) Export Regulations Revised to Ease Burma Controls, Reflect NSG Understandings, Modify Russian Sanctions (December 27, 2016) Export Controls on Chemicals and Biological Agents Updated (December 16, 2016) Illegal Exports to Iran Yield Prison Sentence (December 15, 2016) One Removed from List of Chinese Validated End-Users for High-Tech Exports (December 5, 2016) BIS Removes Certain Nuclear Nonproliferation Export Controls (November 28, 2016) Export Controls on Military Aircraft and Gas Turbine Engines Modified (November 21, 2016) Voluntary Self-Disclosure of Export Violations Info Collection Under Review (November 18, 2016) Suspension of Restrictions on Exports to Two ZTE Entities Extended (November 18, 2016) OFAC to Hold Symposium on Economic Sanctions Dec. 7 (November 15, 2016) Export Control Reform Will be Ongoing Process, BIS Official Says (November 7, 2016) International Export Control Regimes Active in 2016, U.S. Official Reports (November 3, 2016) Export-Controlled Technical Data and Technology is Focus of Defense Dept. Proposal (November 3, 2016) Prison Sentence, Substantial Fine Possible for Unlicensed Exports to Iran (October 31, 2016) Export Privileges Suspended for Unlicensed Exports to Turkey (October 25, 2016) Export Controls Expert Steven Brotherton Joins Sandler, Travis & Rosenberg as Practice Group Leader (October 18, 2016) New DOJ Guidance on Self-Disclosing Export Controls Violations Could be Problematic (October 18, 2016) BIS Discontinues Info Collection Regarding Triangular Transactions (October 18, 2016) Guidance and Fire Control Equipment Among Items Transferred to Commerce Control List (October 12, 2016) Export Control Advisory Committees to Meet (October 5, 2016) Export Regulations Revised to Reflect Changes to Dual-Use Goods List, Entity List (September 20, 2016) Defense Export Regulations Amended to Reflect Revised Definitions (September 12, 2016)

8 Foreign Policy-Based Export Controls Subject of Annual BIS Review (September 9, 2016) Prison Sentence for Attempting to Export Sensitive Technology for Pakistani Military (September 5, 2016) $90,000 Penalty for Unlicensed Export to Restricted Pakistani Entity (August 26, 2016) Aiding Exports to Mexico for IMMEX Operations is Aim of BIS Proposal (August 23, 2016) Exports of EAR-Regulated Goods to Ten Foreign Entities Restricted (August 23, 2016) BIS Extends Suspension of Restrictions on Exports to Two ZTE Entities (August 19, 2016) Destination Control Statements Harmonized for ITAR and EAR Exports (August 18, 2016) BIS Reviewing Information Collection on Export Controls (August 16, 2016) Export Controls Imposed on Specified Nuclear Reactor Parts (August 8, 2016) Chemical and Biological Agents Among Items Transferred to Commerce Control List (July 28, 2016) Export Violation Penalties Eased in Light of Criminal Sentences (July 27, 2016) Ten-Year Prison Sentence for Illegally Exports of Controlled Technology to Russia (July 25, 2016) State Department Relaunches Program to Visit Defense Exporters, Manufacturers and Brokers (July 20, 2016) Fifteen-Month Prison Sentence for Trafficking in Counterfeit Computer Chips (July 13, 2016) $9.4 Million Penalty for Unlicensed Exports; Remedial Actions Help Earn Mitigation (July 6, 2016) Prison Sentence, Fine for Man Convicted of Smuggling Electronics to Russia (July 6, 2016) Nonproliferation Measures Imposed for Shipments to Iran, North Korea and Syria (July 5, 2016) List of Chinese Validated End-Users for High-Tech Exports Modified (June 24, 2016) Alleged Evasion of Export Controls Yields $250,000 Penalty (June 23, 2016) BIS Revises Guidelines on Administrative Penalties for Export Violations (June 22, 2016) Exports Restricted to 36 Persons Added to Unverified List (June 22, 2016) $575,000 Penalty for Illegal Exports of Controlled Items to China (June 10, 2016) Export Controls on Chemicals and Biological Agents Updated (June 7, 2016) Committees on Export Administration, Sensors and Instrumentation to Meet (June 7, 2016) Definitions, Other Changes Made to Defense, Dual-Use Export Regulations (June 3, 2016) Three-Year Prison Sentence for Violating Iran Sanctions (May 25, 2016) Arms Embargo on Vietnam Lifted (May 25, 2016)

9 Export Committees on Regulations, Emerging Technology to Meet (May 25, 2016) Trade in Four Species of Freshwater Turtle to be Monitored (May 24, 2016) U.S., EU Seek to Reassure Traders on Doing Business with Iran (May 23, 2016) State Dept. Reviewing Information Collection on Exports of Unclassified Defense Articles (May 19, 2016) Short Supply License Requirements for Crude Oil Exports Removed (May 12, 2016) Prison Sentence for Illegal Defense Exports, Providing Substandard Parts (April 19, 2016) Specially Designed to be Focus of April 27 BIS Webinar (April 14, 2016) Export Control Regulations Amended to Reflect Missile Technology Regime Changes (April 5, 2016) Coalition Seeks Completion of Export Control Reform Efforts, Eyes Long-Term Changes (March 31, 2016) Prison Time, Forfeiture for Illegal Defense Exports to China (March 7, 2016) U.S. to Pursue Renegotiation of Cybersecurity Export Rule (March 3, 2016) $305,000 Penalty for Alleged Violations of Cuban Sanctions (March 1, 2016) Restrictions on Exports of Dual-Use Goods to Foreign Entities Modified (February 23, 2016) Proposed Transfer of Guidance and Control Equipment to Commerce Control List Revised (February 19, 2016) Export Privileges Suspended for Unapproved Export to Russia (February 17, 2016) Export Committees on Transportation, Materials and Emerging Technology to Meet (February 17, 2016) Training Vital to Prevent Transactions in Regions at High Risk for Sanctions Violations, OFAC Says (February 8, 2016) White House Further Eases Restrictions on Commercial Relations with Cuba (January 27, 2016) No Changes to International Boycott Country List (January 27, 2016) Commodity Jurisdiction Form for Defense Articles and Services Under Review (January 21, 2016) U.S. Lifts Nuclear-Related Sanctions Against Iran (January 20, 2016) Export Controls Advisory Committees Looking for New Members (January 14, 2016) Export Licensing Proposal on Cybersecurity Items to be Revised, BIS Chief Says (January 14, 2016) Export Controls on Sensors and Information Systems to be Discussed at BIS Meetings (January 13, 2016) Nearly $1 Million in Penalties for Attempt to Smuggle Dual-Use Item to Iran (January 11, 2016) Cyber Sanctions Regulations Issued; More Comprehensive Rules to Come Later (December 31, 2015) Exports of Dual-Use Goods to 16 Foreign Entities Restricted (December 29, 2015)

10 Wassenaar Countries Review Work to Strengthen Defense and Dual-Use Export Controls (December 21, 2015) USML Provision on Military Electronics Temporarily Revised to Clarify Export Controls (December 16, 2015) $50,000 Fines for Company, Individual for Unlicensed Export to Venezuela (December 15, 2015) Temporary General License Will Support Exports To and From Burma (December 9, 2015) BIS Makes Corrections to Export Administration Regulations (December 4, 2015) $1.5 Million Penalty for Exports to Iran, Syria and Sudan (November 30, 2015) U.S. Imposes Sanctions Against Certain Burundi Officials (November 30, 2015) Remaining Economic Sanctions Against Liberian Entities Lifted (November 17, 2015) Restrictions on Exports of Dual-Use Goods to Foreign Entities Modified (November 11, 2015) Export Committees on Materials, Transportation Equipment to Meet (November 5, 2015) Fraudulent Exports of Vehicles to China Net Prison Sentence, Forfeiture and Restitution (November 4, 2015) Two Changes to List of Chinese Validated End-Users (October 28, 2015) $50,000 Fine, Eight Year Prison Sentence for Attempted Military Tech Exports to Iran (October 27, 2015) OFAC Action Highlights Need to Keep Sanctions Lists Updated (October 23, 2015) Export Control Compliance Requirements for DOE Contracts Clarified (October 23, 2015) $787 Million in Penalties for Thousands of Financial Transactions for Sanctioned Entities (October 22, 2015) Export Committee on Sensors and Instrumentation to Meet (October 21, 2015) Export Control Reform Architect Takes Over as DDTC Chief (October 15, 2015) Validity of Export Licenses, Agreements Extended for Items Transitioning from USML to CCL (October 13, 2015) U.S. Commerce Secretary Inaugurates Regulatory Dialogue in Cuba (October 12, 2015) Export Privileges Suspended for Unapproved Export to the Philippines (October 12, 2015) Export Control List Changes for Military Vehicles and Vessels, Etc., Under Review (October 9, 2015) New Restrictions on Exports to 12 Persons Added to Unverified List (October 7, 2015) Company Fined, Required to Audit Export Controls Due to Illegal Export (September 29, 2015) $7 Million Penalty for Exports to Syria; All but $250,000 Suspended (September 24, 2015) Export Privilege Suspension for Unlicensed Shipments to Russia Extended (September 18, 2015) Foreign Policy-Based Export Controls Subject of Annual BIS Review (September 14, 2015)

11 $3.5 Million in Fines for Illegal Exports and Reexports of Armored Vehicles (September 3, 2015) Exports of Dual-Use Goods to 29 Foreign Entities Restricted (September 3, 2015) $1.7 Million Penalty Against Bank for Processing Transactions for Sanctioned Entity (August 31, 2015) Special Comprehensive License Authorization for Exports Eliminated (August 26, 2015) Canada Issues General Export Permit for Dual-Use Goods and Technology to Some Destinations (August 18, 2015) Company Fined for Exports to Restricted Entity in China (August 17, 2015) OFAC Offers Guidance on Avoiding Transactions Seeking to Evade Crimea Sanctions (August 10, 2015) Export Privileges Suspended for Unapproved Export to China (August 10, 2015) Exports of Dual-Use Goods Restricted to Russian Oil Field (August 7, 2015) Penalty for Dealing with Iran Sharply Reduced for Struggling, Cooperative Company (July 31, 2015) $500,000 Penalty for Unlicensed Exports of Controlled Items (July 29, 2015) Criminal Fine, Civil Penalty, Suspension of Export Privileges for Unlicensed Dual-Use Export (July 28, 2015) Exports of Dual-Use Goods Restricted to Ten Foreign Entities (July 28, 2015) EAR Amended to Implement Cuba s Removal from List of State Sponsors of Terrorism (July 22, 2015) Export Committees on Sensors, Materials to Meet (July 21, 2015) Removal of Economic Sanctions on Iran Not Expected Soon Despite Potential Nuclear Deal (July 16, 2015) BIS Corrects Rules on Shift of Spacecraft Systems to Commerce Control List (July 13, 2015) Venezuela Sanctions Regulations Issued; More Comprehensive Rules to Come Later (July 10, 2015) Export Control Reform Activities to be Among Topics of BIS Meeting (July 9, 2015) USML Provision on Military Electronics Temporarily Revised to Clarify Export Controls (July 2, 2015) Export Privileges Suspended for Transshipments to Iran (June 26, 2015) $75,000 Fine for Exports of Controlled Items to China (June 25, 2015) Bank Fined $28,800 for Processing Transactions Involving Blocked Person (June 24, 2015) Company Fined Nearly $400,000 for Shipment to China on Iranian Vessel (June 23, 2015) Chemical and Biological Agents Among Items Proposed for Transfer to Commerce Control List (June 17, 2015) Export Controls on Chemicals and Biological Agents Updated (June 16, 2015) Chemical Import/Export Reporting Requirement Under Review (June 10, 2015)

12 Export Privileges Suspended for Unlicensed Ammunition Exports to Mexico (June 8, 2015) Exports of Dual-Use Goods Restricted to Ecuador Telecom Utility (June 4, 2015) Definitions, Other Changes Proposed for Defense, Dual-Use Export Regulations (June 3, 2015) Deemed Exports, Export Control Reform Among Topics of Upcoming Meeting (June 1, 2015) Defense Exports Again Allowed to Fiji (May 29, 2015) Defense Service Provider Registration and Licensing Requirements Clarified in DDTC Rule (May 26, 2015) Export Administration, Regulation Panels to Meet (May 26, 2015) Export Control Documents Could Require More Information Under BIS Rulemaking (May 22, 2015) Harmonization of Destination Control Statements for ITAR, EAR Exports Proposed (May 22, 2015) Preventing Unauthorized Reexports to Russia is Aim of Additional BIS Guidance (May 22, 2015) Exports of Internet-based Communications to Crimea Eased Under New Rules (May 22, 2015) Export Control Regulations Revised to Reflect Wassenaar Changes (May 21, 2015) Former Company President Gets Two Years in Prison for Unlicensed Exports (May 18, 2015) Company, Owner Penalized for Violating Export Denial Order (May 8, 2015) $9 Billion Penalty Against Financial Institution for Violating Economic Sanctions (May 6, 2015) Guidance and Control Equipment Proposed for Transfer to Commerce Control List (May 5, 2015) Two Sentenced to Prison for Scheme to Illegally Export Controlled Items (April 29, 2015) Exports of Dual-Use Goods Restricted to Eight Foreign Entities (April 21, 2015) Company Fined for Providing Services to Sanctioned Drug Trafficker (April 17, 2015) Removal of Cuba from Terrorism Sponsor List Not Likely to Impact Business (April 16, 2015) Defense Trade Controls Licensing Reorganizing in Wake of Export Control Reforms (April 14, 2015) Export Committees on Sensors, Information Systems, Transportation, Materials to Meet (April 14, 2015) Syrian Sanctions Eased to Allow More Transactions Concerning Publications (April 13, 2015) Exports of Military Technical Data to India Yield $250,000+ Penalty (April 9, 2015) Foreign Cyber Criminals Targeting Trade Secrets May See Sanctions Under New Policy (April 8, 2015) Export Control Regulations Amended to Reflect Missile Technology Regime Changes (April 8, 2015) U.S. Bans Trade in Protected Animal and Plant Species with Three Countries (April 7, 2015)

13 Export Privileges Suspended for Unlicensed Shipments of Defense Articles (April 2, 2015) Export Privileges Denied, Penalty Assessed for Violating Temporary Denial Order (March 31, 2015) $780,000 Penalty for Conspiracy to Transfer Funds to Iraq (March 30, 2015) New Paperwork Requirement for Exports of Military Drones (March 30, 2015) Export Privileges Suspended for Unlicensed Shipments to Russia (March 26, 2015) Taiwan Businessman Sentenced to Prison for Conspiring to Violate Nonproliferation Laws (March 19, 2015) Stronger Export Enforcement Efforts are Facilitating Trade, Official Says (March 18, 2015) BIS Revises Support Document Requirements for Export License Applications (March 13, 2015) Export Regulations and Procedures Committee to Discuss Enforcement, AES (March 10, 2015) Two Additional Items May be Exported to Chinese Validated End-User (March 5, 2015) Agencies Examine How Export Control Reform Changes are Working (March 2, 2015) Export Panel to Review Reform Impact on Licensing, Integrated List Review (March 2, 2015) Controls on Exports of Nuclear Energy Technology and Assistance Updated (February 27, 2015) Export Advisory Committee on Emerging Technology and Research to Meet (February 27, 2015) U.S. Unveils Export Policy for Military and Commercial Drones (February 19, 2015) Export Committees on Materials Processing Equipment, Materials, Transportation Equipment to Meet (February 19, 2015) Exports of Dual-Use Goods Restricted to 11 Entities in China, Pakistan and UAE (February 18, 2015) Regulated Export Advisory Committees Seek New Members (February 18, 2015) Restrictions on Exports of Personal Communications Items to Sudan Relaxed (February 18, 2015) Better Collaboration Needed on Export, Other Measures to Protect Advanced Technologies (February 17, 2015) Export Privileges Suspended for Unlicensed Exports to Iran (February 12, 2015) BIS Proposes Removing International Export Control on Dry Etching Equipment (February 9, 2015) Exports of Controlled Items to Crimea Generally Prohibited Under BIS Rule (January 29, 2015) New Restrictions on Exports to 14 Persons Added to Unverified List (January 29, 2015) $90,000 Penalty for Aiding Illegal Export (January 27, 2015) Export Controls on Shipments to India Relaxed (January 23, 2015)

14 Export Privileges Suspended for Attempted Export of Small Arms to Honduras (January 20, 2015) New Regulations Implement Relaxed Trade and Other Policies Toward Cuba (January 16, 2015) Export Controls on Crude Oil and Petroleum Products Outlined (January 15, 2015) New Format for OFAC Sanctions List Released (January 9, 2015) Dual-Use Export Control Changes Agreed by Wassenaar Arrangement Members (January 6, 2015) State Dept. Provides Limited and Temporary Iranian Sanctions Relief (December 31, 2014) Export Privileges Suspended for Weapons Shipments to Mexico, China (December 30, 2014) Corrections and Clarifications Made to U.S. Export Control Regulations (December 29, 2014) BIS Expands, Clarifies Export Controls on Certain Products (December 23, 2014) Labeling Requirements for Pesticide Exports Clarified (December 19, 2014) BIS Expands Microprocessor Military End-Use and End-User Control (December 17, 2014) BIS Issues Advisory Opinion on Application of Export Controls to Cloud-Based Storefronts (December 2, 2014) Export Privileges Suspended for Shipping Certain Weapons to Russia (December 1, 2014) New DOC Web Tool Launched to Help Companies Comply with Export Laws (November 25, 2014) Export Committees on Emerging Technology, Regulations and Procedures, Export Administration to Meet (November 25, 2014) Nuclear Export Controls Need Improvements to Reduce Delays, Tighten Enforcement (November 20, 2014) $2.1 Million Penalty for Purchasing Items Made of Cuban-Origin Material (November 17, 2014) Export Privileges Suspended for Shipments of Aircraft Parts to Iran (November 12, 2014) Final Rules Clarify Shift of Spacecraft Systems to Commerce Control List (November 11, 2014) State Dept. Eases Rules on Exports of Defense Articles and Services to Vietnam (November 10, 2014) License Requirement Imposed on Certain Exports for Military End Use in Venezuela (November 7, 2014) Export Privileges Suspended for Unlicensed Shipment of Carbon Fiber to China (November 7, 2014) Transshipments Through UAE to Iran Yield Fine for Texas Company (November 4, 2014) Supporting Health Care Policies for Blacklisted Persons Nets Fine for Florida Companies (October 31, 2014) Export Committees on Materials, Transportation Equipment to Meet (October 24, 2014) OFAC Guidance on NGO Exports of Aid to Areas Dominated by Blocked Persons (October 23, 2014)

15 Export Committee on Information Systems to Meet Nov. 5-6 (October 22, 2014) New Export Licensing Requirements Imposed on Dual-Use Items (October 13, 2014) California Company Fined $750,000 for Unlicensed Exports of Encryption Software (October 10, 2014) Clarifications to Defense Trade Regulations Changes Reflecting Export Control Reforms (October 10, 2014) New Jersey Company and President Denied Export Privileges for Unlicensed Shipment to China (October 6, 2014) Export Privileges Suspended for Unlicensed Exports of Rifles to Mexico (October 3, 2014) Improving Export Recordkeeping Requirements is Subject of BIS Inquiry (October 1, 2014) Evasion of Export Controls Yields $8 Million in Fines for Hong Kong Entities (September 23, 2014) BIS Implementation of Export Control Reform Needs Some Improvements, Report Says (September 19, 2014) 28 Added to List of Entities Restricted from Receiving Exports of Dual-Use Goods (September 18, 2014) U.S., EU Intensify Economic Sanctions Against Russia (September 15, 2014) BIS to Determine Availability of Certain Controlled Etching Equipment in China (September 8, 2014) Licensing of Agricultural Shipments to Cuba is Subject of BIS Comment Request (September 5, 2014) Foreign Policy-Based Export Controls Subject of Annual BIS Review (September 4, 2014) Bank Fined for Payment for Goods Shipped to Sudan Not Caught by Screening Software (August 29, 2014) Export Regulations, Materials Export Committees to Meet (August 28, 2014) Export Committee on Transportation and Related Equipment to Meet Sept. 10 (August 27, 2014) BIS Officials Review Export Enforcement Activity, Recommend Compliance Measures (August 19, 2014) Export Control Reform Making Progress, Yielding Benefits, Officials Say (August 18, 2014) OFAC Updates Guidance on Entities Owned by Persons Whose Property is Blocked (August 14, 2014) U.S., EU Ramp Up Economic Sanctions Against Russia (August 13, 2014) Export Regulations Updated to Reflect Nuclear Suppliers Group Changes (August 7, 2014) Export Regulations Amended to Reflect Changes to Dual-Use Goods List (August 4, 2014) 16 Added to List of Entities Restricted from Receiving Exports of Dual-Use Goods (August 1, 2014) $16.5 Million Penalty Against Bank for Processing Transactions for Blocked Individuals (July 30, 2014) Expanded Restrictions on Exports to Russia Include Addition of 11 Parties to Entity List (July 21, 2014) Export Committee on Materials Processing Equipment to Meet Aug. 5 (July 14, 2014)

16 Central African Republic Sanctions Regulations Issued; More Comprehensive Rules to Come Later (July 8, 2014) $9 Billion in Penalties for Multi-Year Scheme to Violate U.S. Sanctions (July 3, 2014) Export Committees on Information Systems, Sensors and Instrumentation to Meet (July 3, 2014) South Sudan Sanctions Regulations Issued; More Comprehensive Rules to Come Later (July 3, 2014) Export Controls on Military Electronic Equipment Streamlined (July 1, 2014) List of Entities Restricted from Receiving Exports of Dual-Use Goods Updated (June 26, 2014) California Company Fined $10 Million for AECA and ITAR Violations (June 23, 2014) Jail Sentence for Exporting Controlled Optical Gunsights to Germany (June 23, 2014) New Restrictions on Exports to 29 Persons Added to Unverified List (June 16, 2014) $21 Million Penalty for Illegal Exports and Reexports of Aircraft Parts and Technology (June 10, 2014) Companies Debarred from Defense Trade Activities for Unauthorized Exports (June 10, 2014) 26 Added to List of Entities Restricted from Receiving Exports of Dual-Use Goods (June 5, 2014) Export Regulations Corrected, Clarified for Six Recent Final Rules (June 5, 2014) Changes to Expedited High-Tech Exports to Validated End-Users in China (May 29, 2014) Export Topics to be Discussed at Upcoming Meetings (May 28, 2014) Freight Forwarder to Pay $125,000 for Exports of Monitoring Devices to Syria (May 27, 2014) Export Control Regulations Revised for Changes in Missile Control Regime (May 27, 2014) Export Privileges Denied for Unlicensed Exports of Rifle Parts to Honduras (May 20, 2014) Spacecraft Systems Moved to Commerce Control List; Input Sought on Effect on Satellites (May 13, 2014) Syrian Sanctions Regulations Updated to Reflect Executive Orders and General Licenses (May 2, 2014) Nine Added to List of Entities Restricted from Receiving Exports of Dual-Use Goods (May 1, 2014) U.S. Expands Restrictions on Exports to Russia, Warns on Marking of Imports from Crimea (April 29, 2014) $45,000 Fine for Unlicensed Exports of Controlled Items to Spain (April 29, 2014) Five-Year Record Retention Requirement for Export Transactions Under Review (April 29, 2014) Export Committees on Materials, Materials Processing Equipment to Meet (April 22, 2014) Arms Export Regulations Amended to Reflect Embargo Against Central African Republic (April 21, 2014) Texas Company Sees Majority of Penalties for Exporting to Iran Suspended (April 15, 2014)

17 License Requirements on Certain Exports to Iran Eliminated (April 9, 2014) Export Committees on Info Systems, Instrumentation, Transportation Equipment to Meet (April 7, 2014) California Company Fined $85,000 for Exports of Marine Antenna Systems for Iranian Ships (April 4, 2014) Company Gets Mitigated Penalty for Supplying Fuel to Iranian Vessel (April 2, 2014) BIS Info Collection on Exports of U.S.-Origin Technical Data Under Review (March 31, 2014) U.S. Suspends New Export Licenses for Dual-Use Goods, Defense Articles and Services to Russia (March 28, 2014) Export Control Regulations on Biological/Chemical Goods Updated (March 26, 2014) Dutch Company Fined for Reexports to Syria (March 26, 2014) Export Privileges Suspended for Man Convicted of Exporting Controlled Items to Belarus (March 13, 2014) BIS Meeting to Review Export Control Reform Efforts (March 11, 2014) Defense Company Fined $20 Million, Subject to Extensive Remedial Measures for Export Violations (March 10, 2014) $504,225 Penalty for Illegal Transshipments to Iran (March 10, 2014) Export Committee on Emerging Technology and Research Activities to Meet March 12 (February 25, 2014) Export Committees on Regulations, Materials Processing Equipment, Transportation Equipment to Meet (February 17, 2014) Routed Export Transaction Would be Removed from Export Regs Under BIS Proposal (February 6, 2014) Voluntary Self-Disclosures of Export Violations Under Review (January 28, 2014) BIS Examines Application of New Definition of Specially Designed (January 24, 2014) Technical Data Letters of Explanation Under Review by BIS (January 23, 2014) BIS Recruiting Members for Controlled Export Advisory Committees (January 22, 2014) Export Committee on Materials to Meet Feb. 6 (January 22, 2014) Canada Allows Electronic Export Reporting of Controlled Goods with Multiple Permits (January 17, 2014) Five-Year Record Retention Requirement for Parties to Export Transactions Under Review (January 16, 2014) BIS Reports on Export Control, Enforcement and Penalty Actions for FY 2013 (January 14, 2014) Export Privileges Suspended for Shipment to Iran (January 8, 2014) Exporters Encouraged to Know if Foreign Customers Need Licenses (January 6, 2014) Illegal Reexports Yield Fine for UK Company (January 6, 2014)

18 Inadequate Oversight of Export Coordinator Cited in $500,000 Fine for Illegal Exports (January 3, 2014) More Items Moved from U.S. Munitions List to Commerce Control List (January 3, 2014) Russian Company Removed from List of Entities Restricted from Receiving Dual-Use Exports (December 31, 2013) Bank Fined for Inadequate Efforts to Prevent Terrorism Sanctions Violations (December 19, 2013) Export Privileges Suspended for Illegal Defense Exports, Iran Sanctions Violations (December 19, 2013) Exports to Unverified Parties Get Improved Oversight Under BIS Rule (December 19, 2013) Export Controls Agreed on Electronic Surveillance Tools (December 17, 2013) BIS Amends List of Entities Restricted from Receiving Exports of Dual-Use Goods (December 13, 2013) BIS Reviewing Special Comprehensive License Forms (December 10, 2013) Former Export Compliance Officer Barred from Defense Trade for Export Violations (December 3, 2013) U.S. Government Imposes $252 Million Penalty on Oil/Natural Gas Supplier for Export, FCPA Violations; Civil Penalty for Export Violations is Largest in History (December 2, 2013) Export Committees on Emerging Technology, Regulations and Administration to Meet (November 27, 2013) BIS Reviewing Information Collection on Foreign Availability (November 22, 2013) Defense Trade Office Names New Directors of Compliance and Licensing (November 21, 2013) Canada Proposes to Ease Process to Authorize Exports of Dual-Use Goods (November 14, 2013) 37 Individuals Barred from Defense Trade for Export Violations (November 7, 2013) $300,000 Penalty for Illegal Defense Exports to China and India (October 31, 2013) Export Committee on Materials to Meet Nov. 14 (October 31, 2013) Export Advisory Committees to Meet (October 24, 2013) BIS Resumes Export Licensing Activity, Warns of Delays (October 21, 2013) Defense Trade Controls Office Gets New Chief (October 18, 2013) White House Trumpets Progress on Export Control Reform (October 17, 2013) AES Ready to Handle Filings Under New Export Control Rules Beginning Oct. 15 (October 15, 2013) Defense Trade Controls Agency Still Open for Normal Operations (October 15, 2013) Forwarder Hit With $27,000 Penalty for Violating BIS Denial Order (October 14, 2013) First Export Control Reform Rules Take Effect Oct. 15 (October 11, 2013)

19 Export Violations Yield Penalties, Suspension of Export Privileges (October 8, 2013) Export Regulations See Numerous Changes on CCL, Export Control Reform, Shipping Tolerances (October 7, 2013) Sensors and Instrumentation Advisory Committee to Meet Oct. 29 (October 1, 2013) Export Privileges Suspended, Fines Levied for Illegal Exports (September 27, 2013) Exports of Natural Gas to Non-FTA Countries Approved from Maryland Facility (September 17, 2013) Improved Oversight of Exports to Unverified Parties is Aim of BIS Rule (September 11, 2013) Expedited High-Tech Exports Now Available to Additional End-User in China (September 6, 2013) Foreign Policy-Based Export Controls Subject of Annual BIS Review (September 5, 2013) State Dept. to Begin Processing Commodity Jurisdiction Requests in Line with New Rules (September 4, 2013) Export Administration Panel Holds Open Meeting Sept. 18 (September 4, 2013) Transportation and Related Equipment Export Committee to Meet Sept. 11 (August 27, 2013) Export Enforcement and Regulations to be Discussed at Sept. 10 Meeting (August 27, 2013) Conspiring to Export Satellite Technology to Iran Yields Fine, Jail Time (August 21, 2013) Export Privileges Suspended for Unlicensed Rifle Exports to Mexico (August 14, 2013) Split Shipment Requirement in Export Regulations Eased (August 13, 2013) Guidelines on Evaluating Exports to United Arab Emirates (August 13, 2013) $8 Million Fine Could Signal Further Effort to Prevent Unlicensed Defense Exports (August 12, 2013) Export Committees on Information Systems, Materials, Materials Processing to Meet (July 17, 2013) Export Control Regulations Revised for Changes in Missile Control Regime (July 16, 2013) BIS Reports on Export Control, Enforcement and Penalty Actions for FY 2012 (July 10, 2013) Expedited High-Tech Exports Now Available to Two More End-Users in China (July 10, 2013) Numerous Items Moved from U.S. Munitions List to Commerce Control List (July 8, 2013) License Exemption for Exports of Low-Value Firearms Components to Canada (July 8, 2013) Export Committees on Emerging Technology, Sensors and Instrumentation to Meet (July 3, 2013) OFAC Amends Terrorism Sanctions Regulations (June 27, 2013) Export Privilege Denial Orders for Arms Exports to Mexico (June 26, 2013) Defense Export License System to be Shut Down July 3-7 (June 21, 2013)

20 Export Regulations on Dual-Use Goods Revised to Reflect International Agreement (June 20, 2013) DoD Implements Defense Trade Cooperation Treaties with Australia, UK (June 17, 2013) Export Declaration for Defense Technical Data or Services Under Review (June 14, 2013) Export Control Requirements to be Added to Energy Regulations (June 12, 2013) Export Regulations Amended for Biological/Chemical Control Regime Changes (June 5, 2013) Changes to Expedited High-Tech Exports to Validated End-Users (June 4, 2013) General License Allows Exports to Iran to Facilitate Personal Communications (June 4, 2013) Defense Trade Treaty with Australia Effective May 16 (May 31, 2013) Spacecraft Systems and Related Items Proposed for Transfer to Commerce Control List (May 29, 2013) Export Enforcement and Regulations to be Discussed at June 11 Meeting (May 28, 2013) Exports of Natural Gas to Non-FTA Countries Approved from Second Facility (May 21, 2013) Businesses Urge More Work on Export Control Reforms (May 14, 2013) Updated Guidelines on Defense Exports to Libya (May 14, 2013) Shipowners Mutual Insurance Group Fined for Economic Sanctions Violations (May 13, 2013) Webinars/Events Export Control 201: Mastering the International Traffic in Arms Regulations (June 21, 2018) Export Control 201: Mastering the Export Administration Regulations (April 26, 2018)