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Civil Penalty Imposed to Settle Charges of Illegal Export to Iran

Friday, June 30, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has entered into a settlement agreement with a California man to settle charges that he knowingly exported a used industrial laser system to Iran via the United Arab Emirates without the required authorization. This system is designated EAR99 and subject to the Iranian Transactions and Sanctions Regulations, and under the Export Administration Regulations no person may export or reexport an EAR99 item that is also subject to the ITSR without prior authorization from the Office of Foreign Assets Control.

The agreement provides for a $52,500 civil penalty and denies the man’s export privileges for two years. However, the agreement suspends $45,000 of the penalty as well as the denial for two years provided the man commits no further export violations during that time.

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