Background
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 staying up to date 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, 2022.
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The report highlights government actions taken during a pivotal year for export compliance professionals, who have had to keep pace with a host of new sanctions against Russia and new technology restrictions against China. BIS was especially busy during 2022, rolling out new enforcement policies that allowed it to publish charging letters before cases were resolved and issue settlement agreements without penalties. The agency also issued new temporary denial orders against companies that violated export controls, including notable orders against Quicksilver Manufacturing, Rapid Cut and U.S. Prototype after they illegally outsourced the 3D printing of space and defense prototypes to China.
OFAC also was active, handing out more than $42 million in civil penalties, the most since 2019. The penalties included OFAC’s largest-ever virtual currency enforcement action, a $24 million fine for cryptocurrency exchange Bittrex after it failed to disclose more than 116,000 violations of multiple sanctions programs stemming from deficiencies in its sanctions compliance procedures.
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.