Law360 Runs Akin Trade Partners’ Article on 2024 Outlook for Export Controls and Sanctions

December 12, 2023

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“7 Enforcement Predictions For US Export Controls, Sanctions,” an article by Akin international trade partners Jonathan Poling, Ryan Fayhee and Tyler Grove, has been published by Law360.

The authors begin by discussing the “cautiousness, curiosity and skepticism” among trade lawyers at pronouncements by various government bodies regarding greater enforcement of export controls and sanctions, although the authors note the “great number of task forces and strike forces” that have been established, the increased cooperation between agencies, and the boost in the number of prosecutors in the Justice Department’s National Security Division.

They ask, “[W]hat should companies make of all of this?,” as they point out that recent enforcement actions have been “surprisingly infrequent.” Noting, however, that the Justice Department and the regulatory agencies are “better resourced than ever and…getting more organized,” they offer predictions on how the new approach to enforcement is likely to be applied.

Among them, greater prioritization by law enforcement of export control enforcement around items transiting third countries and ending up in military conflicts; improvement by trade agencies and the Justice Department of coordination of enforcement efforts between and within agencies; and a potential increase in the influence of Congress and other stakeholders on future enforcement activity.

To read the full article, click here.

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