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Texas Company Sees Majority of Penalties for Exporting to Iran Suspended

Tuesday, April 15, 2014
Sandler, Travis & Rosenberg Trade Report

A Texas company has signed an agreement with the Bureau of Industry and Security to settle a charge that it knowingly violated the Export Administration Regulations by transshipping various oil and gas equipment parts to Iran through the United Arab Emirates. According to the agreement, this company concealed and misrepresented the country of ultimate destination of these parts on the Shipper’s Export Declaration or Automated Export System records. The settlement adds that prior to engaging in these transactions the company had knowledge of the U.S. embargo on exports to Iran (e.g., through multiple outreach visits and contacts by U.S. law enforcement agents between 2000 and 2007) and was aware that no authorization from the Office of Foreign Assets Control was obtained for the export of these items.

The BIS has assessed a $250,000 civil penalty against the company for this violation but will suspend $175,000 of that penalty for two years, and waive it thereafter, if during that period the company commits no further export violations and pays the other $75,000. The settlement also suspends the company’s export privileges for five years but provides that this measure will not be enforced if the company pays the $75,000 penalty and commits no further export violations for five years.

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