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$100,000 Penalty for Conspiracy to Export Item to Iran

Friday, September 08, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued an order imposing a $100,000 civil penalty against an Indian company and its owner to settle charges that they conspired to export a U.S.-origin waterway barrier debris system and related components to Iran without authorization from the Office of Foreign Assets Control. This item is designated as EAR99 and is also subject to the Iranian Transactions Regulations.

According to BIS, the conspirators plotted different transshipment routes to Iran to hide the item’s true destination in ways that would also enable them to avoid high shipping fees and duties. They also filed a shipper’s export declaration with the U.S. government that falsely stated that the ultimate consignee was a company in the United Arab Emirates. After the shipment was detained at BIS’ direction, the conspirators reiterated this false statement in communications with BIS and U.S. Customs and Border Protection seeking to obtain the shipment’s release, including on a form BIS-711 (statement by ultimate consignee and purchaser).

The BIS order requires the named entities to only pay $30,000 of the civil penalty. The remaining amount, along with a five-year suspension of the entities’ export privileges, will be suspended for five years and waived thereafter provided that they commit no further export violations during that time.

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