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$837,500 Penalty for Shipping Machine to Iran Through UAE

Monday, December 08, 2014
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has fined a Pennsylvania company and its president for conspiring to circumvent the longstanding U.S. embargo against Iran by exporting a bar peeling machine and related parts from the U.S. to Iran through the United Arab Emirates. This machine is used in high-grade metal processing and finishing and was designated as EAR99 under the Export Administration Regulations. Among other things, the company falsely identified a UAE company as the ultimate consignee on shipping and export documentation.

BIS imposed a civil penalty of $837,500 but suspended $500,000 of it for two years and will waive it thereafter if the company and its president comply with the terms of the plea agreements and commit no further export violations during that time. If the penalty is not paid or the plea agreements are not complied with, BIS may deny the export privileges of the company and/or its president for five years.

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