By: Adrienne Braumiller, Partner and Devin Sefton, Associate Attorney Just last month, Schlumberger Ltd. (Schlumberger), subsidiary Schlumberger Oil Field Holdings Ltd. (SOHL), agreed to pay over $232.7 million in penalties to the United States for violations of the International Emergency Economic Powers Act (IEEPA). Of this amount, $155,138,904, represented a criminal fine. For a number
Sometimes the most efficient solution for our clients involves extending our partnership to provide them with one or more compliance specialists dedicated exclusively to their business, whether that means part-time or full-time, temporary or permanent, even working off-site, or at their office facilities. In a total “turn-key” relationship, we can provide: Auditors (Customs, Export, FCPA)
By: Linnea Deeds, Senior Trade Advisor U.S. government agencies rely heavily on companies worldwide to voluntarily self-disclose export violations. The sheer volume of international transactions makes involuntary enforcement unmanageable. Two export violation cases in 2015 highlight the value and risks of Voluntary Self-Disclosure (VSD). Export violations can involve corporate and individual culpability in civil penalties
By: Paul Fudacz, Senior Associate Attorney Under the NAFTA Rules of Origin, General Note (GN) 12 of the HTSUS, when non-originating materials are used to produce a final product in a NAFTA country, in order for that final product (also referred to as the “Good”) to qualify for NAFTA preferential treatment, the non-originating materials must
By: Bruce H. Leeds, Senior Counsel A number of years ago I attended a 2-day workshop conducted by U.S. Customs. The agency was discontinuing the Compliance Assessment Team approach to conducting audits, and was going to a new method based on what they termed the COSO model. The workshop described the model they were adopting
Joe brings over 35 years of Federal Service experience to Braumiller Consulting Group, LLP. He is the former U.S. Census Bureau’s International Trade Ombudsman and Chief for the Regulations, Outreach, and Education Branch with the United States Census Bureau’s International Trade Management Division. In this position, he worked on regulatory matters pertaining to the Foreign
It’s been six decades of diplomatic separation between Cuba and the U.S., and Barack Obama and Cuban leader Raul Castro nevertheless found a way to sit down together recently in Panama and make a public display of their talks at a regional summit, moving one step closer to restoring diplomatic ties.