The Bureau of Industry and Security has issued an order imposing a $500,000 civil penalty against a Missouri company to resolve charges that it exported globe, gate and butterfly valves controlled for reasons of chemical and biological weapons proliferation to China, Russia and various other destinations without the required BIS licenses. BIS will suspend $350,000 of this penalty for two years and waive it thereafter provided that the company commits no further export violations during that time.

The company will also be required to complete two audits of its export controls compliance program and submit the results to BIS. These audits must be in substantial compliance with the Export Management and Compliance Program sample audit module and must include an assessment of the company’s compliance with the Export Administration Regulations. If the audits identify actual or potential EAR violations the company will have to promptly provide copies of the pertinent air waybills and other export control documents and supporting documentation to BIS.

If the company fails to meet either of these criteria BIS may suspend its export privileges for up to one year.

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ST&R: International Trade Law & Policy

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