$2 Million Penalty for Export Violations

The Bureau of Industry and Security has issued an order imposing a $2 million civil penalty against a U.S. company to settle charges that it committed 66 violations of the Export Administration Regulations.

The company was charged with (1) selling, exporting, transmitting, or servicing design software designated as EAR99 to or for parties on the Entity List without the requisite BIS license or other authorization, (2) thereafter entering into agreements to service and update that software, and (3) exporting a license for software designated aa EAR99 to an entity on the Unverified List without obtaining a UVL statement.

BIS will suspend the penalty for a year and waive it thereafter provided the company takes a number of specified measures, including (1) designating a minimum of two employees or officers to handle export compliance, (2) completing an internal audit of its export controls compliance program, and (3) if that audit identifies actual or potential export violations, promptly disclosing them to BIS.