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$250,000 Penalty, Suspension of Export Privileges for Violation of Temporary Denial Order

Thursday, October 12, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has imposed a $250,000 civil penalty against a United Kingdom man for violating a temporary denial order against him. BIS is also suspending the export privileges of the man and several related companies for four years and requiring the man to continue to fully cooperate with BIS’ investigation of this or other potential export control law violations.

The TDO, which was issued in light of the man’s connections to an Iranian airline also subject to a TDO, prohibited him from directly or indirectly participating in any way in any transaction involving any item subject to the Export Administration Regulations. It also prohibited him from participating in any way in any other activity subject to the EAR, including carrying on negotiations concerning or ordering or buying any item subject to the EAR or benefitting in any way from any transaction involving such an item or from any other activity subject to the EAR.

BIS states that the man violated this TDO by carrying on negotiations concerning and ordering an aircraft engine subject to the EAR. As part of those negotiations, BIS states, he responded to the seller’s concern about his name appearing on a U.S. government sanctions list by misleadingly stating that he only recently had been added to the TDO and was not subject to U.S. government sanctions.

BIS will suspend $150,000 of the penalty for four years, and waive it thereafter, provided the man meets the terms of the settlement agreement and commits no further export violations during that time.

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