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$7 Million Penalty for Exports to Syria; All but $250,000 Suspended

Thursday, September 24, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued an order imposing a $7 million penalty against two individuals and three companies located in Syria or the United Arab Emirates to settle allegations that they violated the U.S. trade embargo against Syria. However, $6.75 million of this penalty will be suspended for two years, and waived thereafter, provided that during this time none of the entities at issue commit any further export violations.

BIS is also suspending the export privileges of these five entities for four to seven years, meaning that for the prescribed period neither these entities nor anyone on their behalf may directly or indirectly participate in any way in any transaction involving any commodity, software or technology exported or to be exported from the U.S. that is subject to the Export Administration Regulations.

These entities are charged with conspiring and acting in concert with others to bring about exports and reexports to Syria without the required U.S. government authorization of computer equipment and software designed for use in monitoring and controlling Web traffic, most of which was controlled for national security and anti-terrorism reasons and as encryption items.

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