This is an update to a blog post originally published on March 10, 2017.

Update:  Last month, the US Bureau of Industry and Security (BIS) decided to remove ZTE Corporation from its Entity List, allowing the company to continue business in the United States. 

“By acknowledging the mistakes we made, taking responsibility for them... we are committed to a ZTE that is fully compliant, healthy, and trustworthy.”

- Zhao Xianming, ZTE President

Amazon.com has dominated the eCommerce industry since 1995, originating as an online reseller of books.  During Amazon’s first month in business, it received orders from customers in 50 U.S. states and 45 countries across the world.  Today, the company offers over 183 million products and serves more than 224 million customers. 

The recent lifting of some Iran sanctions has created considerable interest in the global trading community. However, while there is optimism and hope that a closed market with big investment and opportunity will open to worldwide trade soon, there is also uncertainty. When is the right time for getting back into trading with Iran? Now? Or should we wait a little longer? The messages sent from governments are, at best, mixed. Since mid-January, the EU and the US have formally lifted important elements of their previously enforced strict sanctions. Trade promotion authorities have started setting up trade missions and we read reports about mega-deals being signed. 

According to a recent Reuters article, Commerzbank AG, Germany’s second largest lender, has been ordered to pay $1.45 billion to U.S. authorities. This large fine comes after Commerzbank was accused of laundering money through the United States financial system on behalf of black-listed entities – a big mistake in the eyes of U.S. prosecutors. This signifies the importance U.S. Officials put on restricted party screening and strict compliance with these regulations.

“I’m watching you.” Just as Robert De Niro warned Greg Focker in Meet the Parents, Fokker Services should have realized that the U.S. government was watching too. By doing so, it could have avoided a $21 million fine for exporting U.S.-made goods to Iran, Sudan, and Burma in violation of trade sanctions.

Fokker Services, a subsidiary of the Dutch aerospace company Fokker Technologies Holding BV, admitted to more than 1,100 shipments of banned aircraft parts, technology, and services to sanctioned countries between 2005 and 2010. The $21 million fine represents the value of these transactions.

Talk about a Cuban Export Crisis….CWT B.V., a Dutch travel agency, has been fined $5.9M by the U.S. government for violating the trade embargo to Cuba. CWT’s violations took place from August 8, 2006 to November 28, 2012 and involved trips to Cuba by 44,430 people.

But why, you might ask, is a Dutch company getting fined by the U.S. government? In 2006, CWT became majority-owned by U.S. entities and thus subject to the U.S. Trading With the Enemy Act. CWT continued doing business with Cuba, but without obtaining the necessary licenses issued by Treasury’s Office of Foreign Assets Control (OFAC).

Two executives of an electronic waste recycling company were convicted in December of smuggling, environmental crimes, mail and wire fraud, and obstruction of justice in conjunction with the illegal export of hazardous waste to China and other countries, according to the U.S. Attorney’s Office for the District of Colorado.

Last week the China Nuclear Industry Huaxing Construction Co., Ltd. (Huaxing), a corporation controlled by the People’s Republic of China, pled guilty to violating the International Emergency Economic Powers Act (IEEPA), the Export Administration Regulations (EAR) and other related charges.