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Export Privileges Suspended for Texas Company, Two Officials Over Shipments to Iran

Wednesday, October 22, 2014
Sandler, Travis & Rosenberg Trade Report

A Texas company and two of its officials have agreed to have their export privileges suspended for 10 years to settle Bureau of Industry and Security charges that they illegally exported more than 1,000 computers to Iran through the United Arab Emirates. As a result, until Oct. 18, 2024, 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.

The subject computers are classified under Export Control Classification Number 5A992 and thus controlled for anti-terrorism reasons. As a result, a U.S. government license was required to export these computers to Iran during the time period at issue. The computers were also subject to the Iranian Transaction Regulations, which prohibit direct or indirect exports to Iran of any item subject to both the EAR and the ITR unless authorized by the State Department’s Office of Foreign Assets Control.

According to BIS, none of the three entities at issue sought or obtained any of the required authorizations. In addition, they filed electronic export information falsely stating that the computers were destined for ultimate consignees in the UAE.

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