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DOC News: Export Penalty, Anti-Boycott Penalty, Nuclear Trade Meeting

Monday, July 22, 2019
Sandler, Travis & Rosenberg Trade Report

$300,000 Penalty for Illegal Exports to Iran

The Bureau of Industry and Security has imposed a $300,000 civil penalty against one Iranian company and two of its executives to settle charges that they conspired to violate the Export Administration Regulations. BIS is also suspending their export privileges for ten years.

According to BIS, these parties attempted to transship a micro drill press through the United Arab Emirates to Iran without the required authorization from the Office of Foreign Assets Control. As part of this scheme they directed the U.S. manufacturer to change shipping documentation to list a UAE general trading company as the consignee.

The suspension of export privileges means that none of these entities nor anyone acting 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.

For more information, please contact export compliance attorney Kristine Pirnia.

Penalties for Anti-Boycott Violations

The Bureau of Industry and Security has imposed a $5,000 penalty against a U.S. company to settle charges that it violated the EAR in connection with shipments to Bahrain and Oman. Specifically, the company was charged with (a) furnishing information about business relationships with boycotted countries or blacklisted persons and (b) failing to report the receipt of a request to engage in a restrictive trade practice or foreign boycott against a country friendly to the U.S.

Separately, BIS has imposed a $15,000 penalty against another U.S. company charged with the same violations in connection with shipments to Oman and the United Arab Emirates.

Civil Nuclear Trade Meeting

The Department of Commerce’s Civil Nuclear Trade Advisory Committee will hold a public meeting Aug. 14 in Washington, D.C. This committee provides industry advice on the development and administration of programs to expand U.S. exports of civil nuclear goods and services, including how export policies, programs, and activities will affect the industry’s competitiveness and ability to participate in the international market.

The upcoming meeting will feature an update on the Civil Nuclear Trade Initiative and a discussion of nuclear trade promotion activities. Members of the public wishing to participate in this meeting must notify DOC by Aug. 9.

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