Over the past month, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) has taken a number of actions signaling a substantial change in OEE’s approach to its enforcement of the Export Administration Regulations (“EAR”) under new Assistant Secretary for Export Enforcement Matthew Axelrod. While these actions preview OEE’s stepped-up approach to administrative and criminal enforcement, they also may foretell a recalculation of how companies decide whether and when to...
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