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Paul Ney

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Paul Ney is a partner in the firm’s Government Enforcement & Investigations Practice Group. Paul previously served as head of the National Security Council’s Office of Legal Affairs, as deputy assistant to the president, as deputy White House counsel, and as principal advisor to the president for National Security Affairs. In addition to his government service, he is a registered patent attorney who handled a range of IP litigation matters in private practice.

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Two recent regulatory notices spotlight often overlooked “brokering” obligations for international defense contractors. For companies involved in any aspect of the international defense trade, these notices serve as a useful reminder of companies’ obligations and the need for effective policies to prevent violations.

The Notices

On April 14, 2026, the State Department’s Directorate of Defense…

On February 12, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an enforcement action against IMG Academy, LLC, a school and athletic training facility headquartered in Bradenton, Florida. IMG Academy agreed to pay $1.72 million to settle its potential civil liability for apparent violations of OFAC counternarcotics sanctions. According…