Lately a couple readers have asked for help in finding publicly-released export control settlement and penalty information. I link to these resources often, but perhaps a quick rundown of who publishes what and where might be helpful to some of you:
- Bureau of Industry and Security: BIS wins the prize for openness or at least they would if there was such an honor. The bureau hosts a comprehensive archive of export and antiboycott EAR enforcement documents for cases from the past 5+ years (for older cases check this out). Charging letters, settlement agreements, denial orders, and the odd administrative law judge ruling are all there. BIS gets bonus points for making it easy to find their online FOIA reading room by posting prominent links throughout their site including from the homepage.
- Directorate of Defense Trade Controls: Seek and ye shall find, but not at pmdtc.org. That's because the separate domain assigned to this State Department office (an arrangement I've always found odd) doesn't include any compliance or enforcement case info. But that doesn't mean the documents aren't out there. They are...on State's primary FOIA site. DDTC should really make this stuff easier for folks to find.
- Office of Foreign Assets Control: Beginning in 2003, OFAC began to post civil penalty settlements and assessments to its site on a regular basis (or should I say formerly-regular as their November release is now a month overdue?) Unfortunately, the data supplied is pretty sparse in comparison to either BIS or DDTC. OFAC adopted more of a narrative format this October, but it's only slightly more fact-rich. Somewhat older civil penalty documents are posted to a different part of Treasury's site.
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