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.
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
The Trump Administration has launched a coordinated, whole‑of‑government strategy to “totally eliminate” transnational cartels and affiliated criminal organizations. Two major steps have significantly reshaped the risk landscape for companies with operations in Mexico or that engage in cross-border flows between Mexico and the United States.
First, effective February 20, 2025, the administration designated eight organizations
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping new sanctions targeting Russia’s energy sector, citing the Kremlin’s continued refusal to engage in good-faith negotiations to end the war in Ukraine. The action designates Russia’s two largest oil companies, Rosneft Oil Company (Rosneft) and Lukoil OAO
As we near the Thanksgiving holiday, we wanted to take a moment to thank you — our readers. Eye on Enforcement has been a fun project for the Bradley’s Government Enforcement and Investigations team. But the ultimate goal of any blog is to be read, and we’re grateful to have so many devoted readers. And
Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission (SEC). The enforcement action – the second for the Netherlands-based company – centered on alleged violations of the FCPA’s books-and-records and internal-accounting controls provisions
Concerns over the potential threat posed by information and communications technology (ICT) products and services, such as TikTok, to the United States’ economic and national security have been ruminating for some time now. To tackle that potential threat, on March 7, 2023, a bipartisan group of U.S. senators led by Sen. Mark R. Warner (D)
On October 20, 2022, the Department of Treasury, which houses the Committee on Foreign Investment in the United States (CFIUS), adopted the first-ever CFIUS Enforcement and Penalty Guidelines. The guidelines represent the first written guidance related to how CFIUS will