Alertas de Clientes
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5 Things Defense Contractors Need to Know About DoD’s Proposed Expansion of FOCI Requirements
The Department of Defense’s proposed expansion of Foreign Ownership, Control, or Influence (FOCI) requirements could significantly increase compliance obligations for many uncleared defense contractors, introducing new disclosure, reporting, and mitigation requirements tied to foreign ownership, investment, governance, financing, and business relationships.
OFAC’s $275 million Settlement with Adani Sends a Strong Message to Non-US Companies: Screening Alone Is Not Enough
OFAC’s $275 million settlement with Adani Enterprises underscores growing US sanctions enforcement against non-US companies, emphasizing that restricted party screening and formal compliance programs alone are insufficient when broader transactional red flags suggest potential sanctions evasion risks involving Iran or other high-risk jurisdictions.
BIS Enforcement Action Highlights Risks in De Minimis Calculations for Foreign-Made Items
A recent BIS enforcement action against Teledyne FLIR highlights the risks of misapplying the EAR’s de minimis rule in global supply chains. The case underscores the need for accurate valuation, proper classification of U.S.-origin content, and robust documentation to avoid significant export control penalties.
Export Controls & National Security Round Table
Yormick Law is launching a renewed quarterly Export Controls & National Security Roundtable series, featuring lunch-and-learn sessions focused on key regulatory developments, emerging issues, and practical insights for navigating complex compliance requirements.
Court of Appeals Affirms Transaction Value Applies When Sales are Structured as Domestic, if the Sales Trigger Exportation to the US
The U.S. Court of Appeals for the Federal Circuit affirmed that transaction value applies for customs valuation when sales–regardless of being structured as domestic–trigger the exportation of goods to the United States.
Suspensión temporal de la regla de afiliados de BIS
On 1 November 2025, the White House announced that, effective 10 November 2025, BIS will suspend implementation of the Affiliates Rule for one (1) year in connection with recently concluded, broader trade negotiations with China.