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During his 22 years as a criminal investigator with the U.S. Department of Commerce, Office of Export Enforcement (OEE), Rick led or supervised dozens of national security-focused investigations involving aircraft, electronics, satellites and other commodities controlled by the Export Control Reform Act of 2018 and International Emergency Economic Powers Act. As a recognized subject matter expert, Rick was regularly asked to conduct training across the nation for agents, lawyers and compliance professionals regarding the complex regulations that govern the export of U.S. goods and technology, as well as the necessary elements of an effective compliance program.

For eight years, Rick was the Special Agent in Charge of the Washington Field Office and supervised a dozen criminal investigators and administrative staff. The Washington office handled not only domestic investigations but also foreign investigations involving entities in China, Russia, Ukraine and Iran, among others. Rick’s investigative directives focused on the proliferation of weapons of mass destruction, illicit procurement by terror-supporting countries, and the unauthorized use of military and government technology.

In his role as OEE Assistant Director, Rick supervised a headquarters staff of 17 supervisory special agents, special agents and intelligence analysts in the Operations Division. This group was responsible for reviewing national security intelligence, technical exploitation and law enforcement support to nine OEE field offices. Rick also supervised agents stationed overseas as export attaches and worked closely with the National Security Council and other interagency partners on proliferation issues and interdiction actions.

As part of Husch Blackwell’s White Collar, Internal Investigations & Compliance team, he investigates civil and criminal matters and provides compliance support to clients.

Matthew Axelrod, the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), told a conference held by the Society for International Affairs on May 16, 2022, that his agency is considering major policy changes to its administrative enforcement authorities.  Axelrod said the policy changes, expected to be rolled out in the next few months, are intended to incentivize export compliance by corporations under the Export Administration Regulations (“EAR”). 
Continue Reading BIS Considers More Public and Expensive Consequences for Companies Violating the EAR

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently issued a final rule amending the U.S. Export Administration Regulations (EAR) to add twenty-seven (27) companies and individuals to the BIS Entity List effective November 26, 2021. These companies and researchers are alleged to have ties to China’s military quantum computing efforts as well as Pakistani nuclear and missile proliferation. The new companies added include:
Continue Reading BIS Blacklists Certain Entities with Ties to China, Pakistan and Russia