Blog
Updates on consent agreements, compliance frameworks, and the standards we've integrated into HEXDI.
February 11, 2020 · Matthew Goldstein
Pursuant to the terms of a January 2020 Consent Agreement entered into by the Department of State and Airbus SE (“Airbus”)*, the Department of State and Airbus agreed to settle administrative proceedings for alleged violations of the Arms Export Control Act arising from Airbus’ ITAR Part 130 reports, records maintenance, and re-exports and retransfers of defense articles. […]
Read more →October 10, 2019 · Matthew Goldstein
Pursuant to the terms of a September 2019 Consent Agreement entered into by the Department of State and L3Harris Technologies, Inc. (“L3Harris”) [FN 1], the Department of State and L3Harris agreed to settle administrative proceedings for alleged violations of the Arms Export Control Act arising from activities by Harris Corp. prior to the recent merger between […]
Read more →August 21, 2019 · Matthew Goldstein
On July 30, 2019, the European Union (“EU”) issued the EU Guidance on Internal Compliance Programme (ICP) For Dual Use Trade Controls. [F/N 1] The EU guidance follow release of the European Union Dual Use Coordination Group’s Draft EU Guidance on Best Practices for Internal Compliance Programmes in September 2018. [F/N 2] Same as the draft […]
Read more →July 1, 2019 · Matthew Goldstein
In April 2019, the U.S. Department of Justice Criminal Division released guidance on the Evaluation of Corporate Compliance Programs. [FN 1] The DoJ guidance is intended to assist prosecutors in determining appropriate charging and penalty decisions. For this reason, it is particularly useful to companies in compliance program development, implementation, and maintenance. HEXDI has integrated […]
Read more →June 30, 2019 · Matthew Goldstein
Pursuant to the terms of a March 2019 Settlement Agreement entered into by the Department of Treasury Office of Financial Assets Control (“OFAC”) and Stanley Black & Decker, Inc. (“Black & Decker”), OFAC and Black & Decker agreed to settle Black & Decker’s potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations […]
Read more →May 26, 2019 · Matthew Goldstein
On May 2, 2019, the Department of Treasury Office of Financial Assets Control (“OFAC”) issued a Framework for OFAC Compliance Commitments. [F/N 1] The OFAC Framework strongly encourages organizations subject to U.S. jurisdiction to employ a risk-based approach to sanctions compliance by developing, implementing, and routinely updating a compliance program with at least five essential […]
Read more →January 6, 2019 · Matthew Goldstein
The European Union Dual Use Coordination Group released its Draft EU Guidance on Best Practices for Internal Compliance Programmes in September 2018. [F/N 1] The Draft EU Guidance focuses on exports of dual-use items and lists the following core elements as essential for an effective compliance program: Top-level management commitment to compliance; Organization structure, responsibilities […]
Read more →June 12, 2018 · Matthew Goldstein
Pursuant to the terms of an April 2018 Consent Agreement entered into by the Department of State and FLIR Systems Inc. (FLIR), the Department of State and FLIR agreed to settle administrative proceedings involving multiple alleged violations of the Arms Export Control Act. [F/N 1] As part of the Consent Agreement, FLIR agreed to institute […]
Read more →May 15, 2018 · Matthew Goldstein
Compliance program effectiveness is a factor that U.S. Government agencies consider in deciding whether to criminally charge a company, negotiate a plea, enter into a civil settlement or issue a warning for violations of U.S. export and import laws. Fortunately, the Departments of State, Commerce, Homeland Security, Treasury, Justice, and the Securities and Exchange Commission publish […]
Read more →April 18, 2018 · Matthew Goldstein
HEXDI Module 13 adds new line items to address Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012 (Safeguarding Covered Defense Information and Cyber Incident Reporting). The DFARS clause requires contractors and subcontractors to take certain precautions to safeguard covered defense information, to include employing various security measures, reporting cyber incidents that affect covered defense information, submitting […]
Read more →March 21, 2018 · Matthew Goldstein
We have been hard at work refining and improving both the content and core functionality of HEXDI for the better part of a year. We are exciting to begin inviting folks into the product to give us feedback on how we can continue to improve. If you want to be part of the continued testing, […]
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