Regulatory intelligence for US exporters


Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in keeping pace with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2023.

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The report highlights government investigations, indictments, settlement agreements and penalties during what was a record year for sanctions and export control enforcement, including the largest-ever standalone administrative penalty issued by BIS when it fined Seagate Technology $300 million in April for violating export controls against Huawei. The agency said its 2023 enforcement actions resulted in the most convictions, temporary denial orders and post-conviction denial orders ever issued in a single year (see 2401030074).

BIS also partnered with DOJ to launch more export prosecutions through the new Disruptive Technology Strike Force and continued to unveil changes to its administrative enforcement policies. Those have so far contributed to higher fines for more serious violations and a rise in voluntary disclosures, according to BIS.

OFAC also broke enforcement records, levying the largest civil sanctions penalty in its history when it reached a $968 million settlement with virtual currency exchange Binance in November. The agency's more than $1.5 billion in civil sanctions penalties in 2023 was its most in more than 15 years.

The following summary is divided into two parts: part one details export enforcement actions by BIS, DDTC and DOJ, and part two includes sanctions enforcement penalties administered by OFAC and sanctions indictments, pleas and settlements announced by DOJ.