There is an interesting article in the Wall Journal dated today, March 29, 2024 which says that the U.S. Commerce Department has sent letters to more than 20 U.S. companies with a list of 600 foreign parties that appear to be selling restricted technology to Russia. The full article is here: https://www.wsj.com/articles/export-watchdog-warns-about-counterparties-sending-drone-missile-components-to-russia-d3df4f02?mod=hp_minor_pos10 In addition, the article noted the Justice Deparment’s indictment of a Latvian citizen for conspiracy to sell sophisticated avionics equipment to Russian companies in violation of U.S. export control laws. In a prior article the Journal noted that the Russian Sukhoi 34 fighter bomber relies on parts from the West. It is unclear exactly how those parts are being obtained from US companies as they are restricted by export control laws. One study from the Kyiv school of economics published last month found that 95% of the 2,800 foreign components on found in Russian weapons on the battlefield since the was started were Western and over 70% came from U.S. firms.
In addition, the Commerce bureau has increased collaboration with the Treasury Department’s Financial Crimes Enforcement Network,(FINCEN) which oversees regulation of anti-money-laundering rules and collects reports of suspicious transactions from banks and other financial institutions. FinCEN requested banks to notify it of possible violations of export controls and Russia sanctions in their suspicious transactions reports using dedicated tags.
U.S. companies that know or should know their components might end up with the Russian military should face major fines from U.S. regulators. Such information might warrant rewards under the U.S. agency whistleblower programs.
Jeffrey Newman is a whistleblower lawyer whose firm only represents whistleblowers in, under the securities and Exchange, FINCEN and CFTC whistleblower programs. He can be reached at Jeff@JeffNewmanLaw.com or at 617-823-3217
