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Export Privileges Suspended for Unlicensed Shipments to Russia

Thursday, March 26, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a temporary denial order suspending for 180 days the export privileges of a California company and two of its officers who have been indicted for smuggling and money laundering.

BIS alleges that the company exported items subject to the Export Administration Regulations to Russia without a license via transshipment through third countries and that the company’s Automated Export System filings identified as ultimate consignees companies in Estonia and Finland that operated as freight forwarders rather than end-users. Further, a search of BIS’s licensing database reveals no licensing history of controlled U.S.-origin electronics to Russia for the company and individuals involved here.

Believing that a violation of the EAR is “imminent in both time and degree of likelihood,” BIS has issued a TDO to prevent such violations and advise companies to cease dealing with these entities in export transactions involving items subject to the EAR. Under this order, for 180 days 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 EAR.

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