The Kitchen considers the Directorate of Defense Trade Controls (DDTC) updated guidance to Agreements under ITAR.
Tag: ITAR
State Department’s proposed changes to ITAR’s nationality rule; request for public comment.
Categories
ITAR Sanctions Re: Cambodia
The State Department amends ITAR to restrict trade of defense articles and services with Cambodia.
Categories
Cambodia Update – ITAR
The Kitchen review ITAR: addition of Cambodia to the List of Proscribed Countries.
In this special 5-part podcast series on the FCPA Compliance Report, I am considering the Airbus international anti-corruption enforcement action from a variety of perspectives from some of the top world’s top compliance practitioners and commentators on compliance. They include, Jay Rosen-Mr. Monitor; Mike Volkov-Editor of Corruption Crime and Compliance; Jonathan Armstrong-partner at Cordery Compliance in London; Cecilia Fellouse-Guenkel-Secretary General, The Circle of Compliance and Tom Fox-the Compliance Evangelist. In today’s Episode 2, Mike Volkov considers that US trade sanction enforcement involving Airbus.
Highlights include:
- How was Airbus subject to US trade sanction jurisdiction?
- This is one of the few cases where the DOJ focused on anti-corruption and trade sanctions.
- Airbus had complete absence of commitment to compliance.
- Airbus had a completely broken culture.
- What were the three categories of ITAR violation identified by the DOJ?
Resources
Mike Volkov’s review of the ITAR portion of the US enforcement action here.
