Blog

ITAR Brokering in Foreign Defense Transactions: DS-4294 Approval, Expanding Enforcement, and Hidden Liability Risks

ITAR Brokering in Foreign Defense Transactions: DS-4294 Approval, Expanding Enforcement, and Hidden Liability Risks

Brokering under the International Traffic in Arms Regulations (ITAR) is one of the most misunderstood and increasingly enforced areas of U.S. export control law. Many market participants assume the rules mainly apply to manufacturers and exporters. In reality, enforcement often focuses on intermediaries: consultants, introducers, deal facilitators, and even financial actors involved in defense-related transactions.

Secondary OFAC Sanctions - Enforcement Trends, Case Studies, and Exposure of Non-U.S. Companies

Secondary OFAC Sanctions - Enforcement Trends, Case Studies, and Exposure of Non-U.S. Companies

Over the past decade, especially after the expansion of Russia-related measures in 2022, secondary sanctions have moved from a niche concept to a central pillar of U.S. economic enforcement. Unlike traditional sanctions, which are largely tied to jurisdictional limits, secondary sanctions reach beyond U.S. borders.

Interpol Red Notices and Extradition: What Happens After an International Alert

Interpol Red Notices and Extradition: What Happens After an International Alert

An INTERPOL Red Notice is one of the most powerful and most frequently misunderstood tools in international law enforcement cooperation. It is often described in the media as an “international arrest warrant,” but that characterization is not accurate. A Red Notice is not a warrant and, by itself, does not automatically authorize an arrest in most jurisdictions.

ITAR & AI-Enabled Defense Technologies: Autonomous Systems, Targeting Algorithms, and the New Export-Control Frontier

ITAR & AI-Enabled Defense Technologies: Autonomous Systems, Targeting Algorithms, and the New Export-Control Frontier

Artificial intelligence has moved from research laboratories into deployed defense systems: autonomous ISR platforms, battlefield decision-support engines, predictive logistics tools, electronic-warfare optimization software, and AI-enabled targeting modules.

OFAC 50 Percent Rule: Ownership Aggregation, SDN Risk, and Sanctions Compliance Strategy

OFAC 50 Percent Rule: Ownership Aggregation, SDN Risk, and Sanctions Compliance Strategy

The OFAC 50 Percent Rule is a foundational doctrine of U.S. sanctions enforcement. It provides that any entity owned, directly or indirectly, 50 percent or more in the aggregate by one or more blocked persons is itself treated as a blocked person. Even if the entity does not appear on the SDN List.

OFAC General vs. Specific Licenses Explained: U.S. Sanctions Authorization, Compliance Risks, and Enforcement Protection

OFAC General vs. Specific Licenses Explained: U.S. Sanctions Authorization, Compliance Risks, and Enforcement Protection

Economic sanctions compliance in the United States runs on a strict-liability standard. In plain terms: you don’t have to mean to violate sanctions to be in violation. For businesses, banks, investment funds, law firms, and multinational executives, the difference between an OFAC General License (GL) and a Specific License (SL) isn’t a technical footnote, it can determine whether a transaction moves forward smoothly or turns into a costly enforcement problem.

Facing an Interpol Red Notice? Why an Interpol Attorney Is Critical

Facing an Interpol Red Notice? Why an Interpol Attorney Is Critical

Facing an Interpol Red Notice is a serious international legal event, not a minor administrative issue. Individuals subject to Red Notices frequently encounter airport detentions, travel bans, immigration denials, frozen bank accounts, and long-term reputational damage—often without ever being convicted of a crime.

BIS Investigations: A Comprehensive Guide to Export Control Enforcement and Defense

BIS Investigations: A Comprehensive Guide to Export Control Enforcement and Defense

A BIS investigation is one of the most serious enforcement risks in international trade. The Bureau of Industry and Security (BIS), part of the U.S. Department of Commerce, enforces the Export Administration Regulations (EAR): the rules that control how U.S.-origin goods, software, and technology can be exported, reexported, or transferred between countries.

OFAC Subpoena: Enforcement Risk, Timelines, and Strategic Response Across Industries

OFAC Subpoena: Enforcement Risk, Timelines, and Strategic Response Across Industries

An Office of Foreign Assets Control (OFAC) subpoena is one of the most serious enforcement tools the U.S. Treasury uses in sanctions investigations. While it is administrative in form, it signals a clear shift from routine compliance oversight to active enforcement scrutiny.