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Export Privilege Suspension for Unlicensed Shipments to Russia Extended

Friday, September 18, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has extended an order suspending the export privileges of a California company and two of its officers for another 180 days to prevent imminent violations of the Export Administration Regulations.

The original order was issued based on evidence of a pattern of exports from the U.S. to Russia via transshipment through Estonia or Finland that involved false statements and other evasive actions or schemes designed to camouflage the actual destination, end uses and/or end users of the U.S.-origin items that the company was exporting on an ongoing basis, which included items listed on the Commerce Control List and subject to national security-based license requirements. However, BIS states, the company and the two officers violated this order by repeatedly seeking to order or buy items subject to the EAR from a U.S.-based electronics distributor from which they had previously purchased items for export.

BIS is therefore extending the order to avoid imminent violation of the EAR and provide continued notice to persons in the U.S. and abroad that they should not deal with these entities in connection with any exports, reexports or other transactions involving any items subject to the EAR or any other activities subject to the EAR.

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