Publication
Global Connection – Enhanced Export Regulatory Enforcement
By Brett W. Johnson and T. Troy Galan
In a continued theme of increased enforcement of export controls, the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce released a memorandum that announced a stricter Administrative Enforcement Program. This is particularly relevant as the war in Ukraine continues, the ensuing sanctions packages are only enhanced – especially combined with export sanctions by other countries. Notably, the enhanced penalties and related policy changes announced by the June 30 BIS memorandum apply not only to Russia and Belarus, but to the entire U.S. export controls regime. Companies should be aware of the BIS guidance and the heightened enforcement environment due to ongoing national security threats precipitated by illicit acquisition of U.S. technology.
About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 16 locations throughout the United States and in Mexico, including Los Angeles, Orange County and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
