BIS Enforcement Actions: Everything You've Ever Wanted to Ask a (Former) BIS Special Agent | EMBARGOED Ep. 77

On this week's EMBARGOED!, host Tim O'Toole and Miller & Chevalier's Melissa Burgess, with guest Don Pearce, currently a Senior Advisor with Torres Trade Advisory and a retired BIS Special Agent, discuss the role of BIS Special Agents in enforcement actions, plus updates to BIS enforcement policies, recent enforcement actions, and best practices for industry.

Roadmap:

• Introduction
• The role of BIS Special Agents in enforcement actions (compared with the roles of other agencies like HSI or OEE personnel involved in reviewing disclosures)
• How to respond to outreach or a visit from a BIS Special Agent and related tips 
• Providing tips and investigation leads when industry suspects a customer is attempting to divert products: When should industry approach BIS once it identifies red flags? What kind of information is useful?
• Thoughts about the 2022–present changes to BIS enforcement and voluntary self-disclosure policies, including September 2024 regulatory changes
• Highlights from the newest Don’t Let This Happen to You
• Interesting features or lessons to learn from recent enforcement actions

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Thanks to our guests for joining us:

Don Pearce: https://torrestradeadvisory.com/team/donald-pearce/ 

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess 

Questions? Contact us at [email protected].

EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!