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
Read more →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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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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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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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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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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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
Read more →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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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.
Read more →By Janet Labuda The short answer to the question who’s driving the compliance bus is your corporate compliance department. The driver’s seat, should not be filled with personnel from your transportation and logistics operation, the sourcing, or import management groups. All parts of your organization need to
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