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ITAR & EAR Enforcement Actions: Lessons Learned from 2021 and Outlook 2022

The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and the U.S. Department of Commerce’s Bureau of industry and Security (BIS) both continue to remind the private sector of the importance of strict export control compliance.

In 2021, the U.S. Department of State’s Directorate entered into two settlement agreements with companies for export violations of the International Traffic in Arms Regulations (ITAR). In May with Honeywell International, Inc. (Honeywell) of Charlotte, North Carolina. And in August with Keysight Technologies, Inc. (Keysight) of Santa Rosa, California.

In 2021, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) entered into twenty settlement agreements with companies (not including individuals) for export violations of the Export Administration Regulations (“EAR”).

Throughout the year of 2021, enforcement actions were brought against Avnet Asia Pte., Ltd. (“Avnet Asia”), Princeton University (“Princeton”), MSI Aircraft Maintenance Services International GmbH & Co. (“MSI”), Comtech Xicom Technology, Inc. (“COMTECH XICOM”), Panther Trading Company (“PTC”), SAP SE (“SAP”), FLIR Systems, Inc. (“FLIR”), MDA Precision LLC (“MDA Precision”), Kleiss & Co. BV (“Kleiss”), TeleDynamics LLP (“TeleDynamics”), Alsima Middle East General Trading LLC (“Alsima”), Photonics Industries International Inc. (“Photonics”), USGoBuy LLC (“USGoBuy”), Skyline USA Inc. (“Skyline”), Patriot 3, Inc. (Patriot 3), Alfa Laval Inc (“Alfa Laval US”), Dynatex International (“Dynatext”), Silicon Space Technology Corporation (“SST”), VTA Telecom Corporation (“VTA”), and SP Industries, Inc (“SP Industries”).

During this ACSS webinar we will discuss the “Lessons Learned” from the DTTC and BIS enforcement cases in 2021 and look forward to 2022.

Duration: 75 minutes

Keith Huffman, Chief Legal Counsel, Export Control | SAP
Lynn Van Buren, Global Compliance Counsel | Spire
Kim Canales, Senior Manager, Trade & Customs | KPMG

Moderator: Alexander Witt, Sanctions & Export Controls Consultant, ACSS

CSS Credits: 1

Date: Thursday, January 27, 2022

Time: 12:00 PM – 01:15 PM New York (EST)

05:00 PM – 06:15 PM London (GMT)

06:00 PM – 07:15 PM Amsterdam (CET)

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Keith Huffman

Chief Legal Counsel, Export Control


Keith Huffman is Chief Legal Counsel, Export Control US (Global) at SAP. He is based in the UK but has a global responsibility for compliance with U.S. export control and sanctions laws applicable to all of SAP’s activities. He is responsible for managing SAP’s global export control and sanctions compliance program, adopting and implementing SAP global corporate policies, training on export control and sanctions requirements, classifications, collaborating with legal teams on contract and deal negotiations and advising on corporate strategic projects.

Prior to joining SAP, Mr. Huffman was in private practice in London and Washington, DC for international law firms focusing on assisting clients with export control and sanctions compliance as well as trade policy advocacy work. Prior to his legal career, Mr. Huffman worked in the US Government, focusing on foreign policy, international trade and defense issues.

Lynn Van Buren

Global Compliance Counsel


Lynn Van Buren is the Global Compliance Counsel at Spire Global, Inc., a nanosatellite space-to-cloud data and analytics company. Ms. Van Buren has more than two decades of in-house and private practice global trade compliance experience. Ms. Van Buren received her J.D. from the University of Wisconsin and has an M.A. in international affairs from the Elliott School at George Washington University.

Kim Canales

Senior Manager, Trade & Customs


Kim is a Senior Manager in KPMG’s Trade and Customs Practice, based in Dallas, Texas. She has over 20 years of experience in international trade compliance and sanctions. She has substantial in-house experience, having worked in the telecommunications, military/defense, and global engineering and project management sectors, where she created, implemented, trained, and measured end-to-end compliance programs.

Her most recent experience was serving as a Director of global compliance for a multinational technology and media concern, where she managed global trade and sanctions compliance operations.