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Practice Areas

$575,000 Penalty for Illegal Exports of Controlled Items to China

Friday, June 10, 2016
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued an order fining a Michigan company $575,000 to settle charges that on 20 occasions over three years the company exported items controlled for missile technology reasons to China without the required licenses. However, BIS is suspending $400,000 of the fine for two years and will waive it thereafter if the company commits no further export violations during that time.

The company has also agreed to complete two audits of its export controls compliance program, at least one of which must be conducted by an unaffiliated third party consultant with expertise in U.S. export control laws. If these audits identify actual or potential violations of the Export Administration Regulations, the company will be required to promptly provide copies of the pertinent air waybills and other export control documents and supporting documentation to BIS.

If the company fails to make full and timely payment of the civil penalty or to complete the audits, BIS may suspend its export privileges for one year.

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