Ok, so a guillotine may be just slightly over the top, but it is undeniable that the federal government is enforcing trade with extreme rigor, as seen from our survey results of penalty cases just from the past month. You can see the results from the table we prepared (see below) which captures only a small percentage of recent penalty cases. The agencies involved are the US Department of Justice, Office of Foreign Assets Control, Securities and Exchange Commission, US Department of State, and the Bureau of Industry and Security. Not shown are the import penalty cases imposed by US Customs and Border Protection, the FDA, and other agencies. Adding import penalty cases (if federal authorities ever released that information) would stretch this table to several pages. The penalty amounts total about $400 million, but do not and cannot reflect all the real costs that a violator company must shoulder to deal with compliance emergencies.
Principal and a founding member of GRVR Attorneys.