What Can Now Trigger a Government Investigation of Your Export & Re-Export Activities: How Export Control Reform Has Changed the Enforcement Landscape and Increased Coordination between U.S. and Canadian Officials

January 29, 2014 8:35am

​• How U.S. enforcement officials will treat suspected and actual violations involving former USML items
• What triggers suspicion amid ongoing reforms: Concrete examples, including technical data and hardware exports
• How the agencies decipher between an egregious violation vs. an innocent mistake, and when an innocent mistake could still warrant further investigation and penalties
• How the agencies investigate suspected export violations and collect evidence
• When a case can become criminal: When the Department of Justice will prosecute companies and individuals
• When and how the RCMP gets involved in a case
• The extent of U.S. cooperation with Canadian agencies, and case referrals
• How administrative, civil and criminal penalties are being calculated
• Criminal sentencing trends: Extent of potential jail time
• Practical impact of U.S. export control reform on enforcement and penalties