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Self-Disclosure of Anti-Boycott Violation Helps Company Avoid Penalty

Wednesday, June 13, 2018
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has concluded an anti-boycott investigation of a U.S. company with a warning letter rather than a penalty, citing specifically the company’s voluntary self-disclosure.

According to BIS, in connection with the sale and/or transfer of goods to Korea for sale to third-country customers, the company provided a certification that the goods did not contain Israeli parts or components in violation of Export Administration Regulations provisions prohibiting such acts. Also in connection with that transaction the company violated the EAR by failing to report to BIS its receipt of a request to confirm whether the goods contained any parts or components made in Israel.

However, BIS states that after considering all the facts and circumstances known at this time, including specifically that the company discovered the violations itself and voluntarily disclosed them to BIS, this investigation is being closed with the issuance of a warning letter.

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