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Practice Areas

Export Privileges Suspended for Exports to China and Iran

Thursday, March 28, 2013
By Shawn McCausland
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued separate orders concerning the following violations of the Export Administration Regulations.

- A Virginia man and a company that shared the same address were charged with exporting two phase synthesizers controlled for national security reasons to China without the required license and with misdescribing the value of these items on air waybills. To settle these charges the BIS imposed a $35,000 civil penalty and suspended their export privileges for five years, although these penalties will be suspended provided that the defendants do not commit any further EAR violations during that time.

- A Florida company and its owner, along with two other companies that shared the same address, were all convicted of knowingly and willfully exporting computer and related equipment from the U.S. through the United Arab Emirates to Iran without the required license. BIS has therefore suspended their export privileges for ten years, through Oct. 18, 2022.

- A New York man convicted of knowingly, intentionally and willfully attempting to export, reexport, sell and supply, directly and indirectly, a spindle of carbon fiber from the U.S. to Iran without the required export license has had his export privileges suspended for ten years, through June 21, 2022.

In none of the above cases do the orders prohibit any export, reexport or other transaction subject to the EAR where the only items involved that are subject to the EAR are the foreign-produced product of U.S.-origin technology.

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