Coping With The New Export Control Paradigm

Although the United States has long maintained controls on the export of goods, services and technology, these controls have become a special focus in the post-9/11 world.

The number of enforcement actions is steadily increasing and potential fines have gone up sharply, including through a 2007 increase by the International Emergency Economic Powers Enhancement Act (which applies to dual-use export and sanctions regulations) of the maximum civil penalty from $50,000 per violation to the greater of $250,000 or twice the amount of the violation.

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