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Export Penalty Highlights Need for Compliance Program

Friday, February 01, 2019
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has imposed an $80,000 civil penalty against a New York company to settle charges that it violated the Export Administration Regulations. If the company does not make full and timely payment, BIS may suspend its export privileges for one year.

BIS alleges that the company exported real-time back reflection camera detectors and accessories, which were designated as EAR99, to an entity in China listed on the Entity List without seeking or obtaining the required BIS license. BIS notes that although this company is an experienced exporter it did not have an export control compliance program in place at any relevant time to screen foreign customers against the Entity List or other U.S. export control lists.

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