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Practice Areas

$90,000 Penalty for Aiding Illegal Export

Tuesday, January 27, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued an order imposing a $90,000 penalty against a New Jersey company charged with four counts of violating the Export Administration Regulations. Specifically, BIS states, this company facilitated the export of scrap steel (designated EAR99) from the U.S. to an entity in Pakistan listed on the Entity List. For each export the New Jersey company, acting on behalf of a Canadian company, arranged for the trucking of the scrap steel from the U.S. exporter’s location to the port of export, arranged for the shipping of the scrap steel to the Pakistani company, and prepared and submitted shipping documentation, including a Shipper’s Export Declaration indicating that the export was designated NLR (no license required).

If the company does not pay the penalty in a full and timely manner, BIS may issue an order suspending its export privileges for one year.

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