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Go Ahead and Offer the Senator a Cup of Coffee

Client Alert | less than 1 min read | 02.21.08

As detailed in the attached bullet analysis, the Senate Select Committee on Ethics, in response to the Honest Leadership and Open Government Act of 2007 (“HLOGA”), published new guidance concerning the gift exceptions for items of little intrinsic value and food offered other than as part of a meal. Although the Senate clarifications arguably clear up very little, they are a good reminder that it is time to update company codes of conduct and compliance manuals in light of the many new requirements established by HLOGA.

Insights

Client Alert | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....