It’s my long-held position that technology controls present the most challenging export compliance challenge. Last month’s consent agreement between the Directorate of Defense Trade Controls and Honeywell International illustrates my point quite well. As we’ll discuss, Honeywell fell into three of the most common traps for unauthorized exports of controlled information. Companies subject to the International TrafficRead More »DDTC Consent Agreement Highlights Technical Data Export Challenges
OFAC and BIS regulations SAP, a German multinational software corporation with a significant U.S. presence, recently settled allegations that it violated OFAC and BIS regulations concerning exports of software, upgrades, and patches from the United States to Iran and Iranian companies. The settlement amounts totaled in excess of $6.4 million. In the following transcriptRead More »Settlements for Exports of Controlled Encryption Software to Iran
There are all kinds of annual awards: Razzies for bad films, Golden Mullets for the worst video game and the Turnip Prize for lousy art. That got me to thinking. Maybe another one’s in order, to celebrate the most embarrassing export control penalty of the year. Let’s call it the Dummies. My nomination will be hardRead More »And This Year’s Award Goes To . . .