You are reading the February 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.

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  • February saw a continuing focus on Russia. First, the Treasury Department's Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the "largest number of sanctions imposed since Russia's full-scale invasion of Ukraine." The Commerce Department's Bureau of Industry and Security (BIS) also added 93 entities to its Entity List. Second, the Department of Justice (DOJ) disrupted two separate sanctions evasion schemes with individuals entering guilty pleas.
  • There were three notable actions involving Iran this month. BIS reached an administrative settlement with CargoSave, a freight shipper, which seems to have been granted "credit" for assisting in an investigation of a third party. Also, a UK citizen was sentenced to 18 months in prison for conspiring to export U.S.-origin goods to Iran, and a father-son duo was charged with facilitating the export of a variety of U.S.-origin equipment and technology to Iran.
  • February also saw a flurry of enforcement actions involving China. Boeing agreed to settle 199 Violations of the International Traffic in Arms Regulations (ITAR) when it allowed foreign person employees (FPEs), some residing in China, access to ITAR-controlled files on an internal server. And a U.S. citizen pleaded guilty to conspiring to commit wire fraud after he sourced parts and components from China in violation of contracts with the U.S. government.

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