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Practice Areas

$90,000 Penalty for Unlicensed Export to Restricted Pakistani Entity

Friday, August 26, 2016
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has imposed a $90,000 penalty against a California company described as “an experienced and sophisticated exporter” in connection with an export to an entity in Pakistan on the BIS Entity List. Specifically, the company was charged with selling a large area pulsed solar simulator designated as EAR99 for export with knowledge or reason to know that the intended end user was listed on the Entity List, that a license was required to export this item to that entity, and that no such license had been obtained. According to BIS, the company used export control screening software to screen the names of every party involved in the transaction except the listed entity, which it knew prior to shipment would be the end-user, and failed to screen the ship-to address it had been provided in connection with this transaction. Both omissions contradicted the stated terms of the company’s own export compliance plan.

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