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$230,000 Penalty for Unlicensed Exports to China and Russia

Tuesday, October 03, 2017
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued an order imposing a $230,000 penalty on a U.S. company to settle charges that it committed 18 violations of the Export Administration Regulations by exporting items subject to the EAR to China and Russia without the required BIS licenses. The items at issue were active multiplier chains, which are classified under ECCN 3A001.b.4 and controlled for national security and anti-terrorism reasons.

BIS is suspending $50,000 of the penalty for two years, and waiving it thereafter, provided the company pays the rest of the penalty in a full and timely manner and commits no further export violations during that two-year period. If the penalty is not paid BIS may suspend the company’s export privileges for two years.

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