Under the Obama administration, the U.S. government has significantly intensified its enforcement of U.S. export regulations, resulting in an extraordinary uptick in both civil and criminal penalties. The most prominent of these regulations are the International Traffic in Arms Regulations, enforced by the U.S. Department of State’s Directorate of Defense Trade Controls; the Export Administration Regulations, administered by the U.S. Department of Commerce’s Bureau of Industry and Security; and regulations administered by the U.S. Department of Treasury’s Office of Foreign Assets Control. As discussed in the article, anything but strict compliance with these regulations may expose a company to debarment from U.S. government contracts as well as severe civil and criminal sanctions.
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