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Yearly archive for 2017

Chemical Company and Its Owner Sentenced for Rebate Scheme, False Statements to U.S. Customs

This is not your typical trade compliance case.  Obviously, trade compliance issues are usually easy to address on the front end.  But this worst case scenario event is instructive. In reviewing this case, the sad part is that most of what was accomplished illegally could have been

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Not Your Typical Red Notice Case

Department of Justice Office of Public Affairs FOR IMMEDIATE RELEASE Tuesday, March 7, 2017 ZTE Corporation Agrees to Plead Guilty and Pay Over $430.4 Million for Violating U.S. Sanctions by Sending U.S.-Origin Items to Iran Combined Penalty of $1.19 Billion with Department of Commerce and Department of

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Compliance: what are the trade risks (Part 2)

by [email protected] In 2008, while I was still working for U.S. Customs Border Protection (CBP) on international trade enforcement, information kept arriving from other governments, as well as from the U.S. import community, alleging that textile products were being undervalued on the entry documents submitted to Customs.

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Procurement Fraud and Grant Fraud enforcement programs are likely to be revitalized by the Trump Administration.

It’s no shock that a political change in the Executive Branch leads to an increase in grant fraud and procurement fraud enforcement. The reason? There is low risk in scrutinizing grants and contracts awarded by the outgoing administration. Whatever shenanigans are discovered by a new Administration will

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Department of Energy OIG Enforcement under a Trump Administration

The United States Department of Energy (DOE) is a Cabinet-level department of the United States Government. Its responsibilities include the nation’s nuclear weapons program, nuclear reactor production for the United States Navy, energy conservation, energy-related research, radioactive waste disposal, and domestic energy production. It also directs research in genomics; the Human Genome Project originated in an iniative between DOE, NIH and international collaborators. 

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Compliance: what are the trade risks (part 1)

by [email protected] Over the last few weeks, I have written a series of short articles discussing the need for developing a compliance-based approach to transacting international trade. This will help to prepare your organization to effectively deal with the risks inherent in importing. What are these risks

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Bradford Geyer: I GROSSLY UNDERSTATED INCREASED RESOURCES REQUIRED BY DEPARTMENT OF STATE OIG

In my February 14th Post about an armored car services audit conducted by the Department of State OIG, I threw out the following parenthetical comment: (did I mention that DOS-OIG could be doubled or even tripled in size and it would still not have enough resources?…) In reflecting further

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Bradford Geyer explains we need to keep an eye on #OIG audits

Bradford Geyer sees an enforcement agency storm forming around government grants and government procurement and he argues that contractors and grantees would be well served to keep an eye on OIG audit reports that often telegraph enforcement activity.  He provides a quick primer regarding a Department of

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Compliance: it starts at the top

  by [email protected] Whether you are a small to medium sized enterprise, or a large multinational corporation, creating a culture of compliance starts at the top. This compliance culture should permeate your entire organization starting with the Chief Executive, the Chief Financial Officer, and the corporate counsel.

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Trade Compliance–Why Bother

by Janet Labuda [email protected] I worked in Customs for over thirty years and met regularly with importers to discuss trade risk, compliance, and enforcement. Often, companies would express their concerns about the cost of compliance–the proverbial cost benefit analysis. If money is spent to create a compliance

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