Background

The Bureau of Industry and Security has issued an order imposing a $700,000 civil penalty against a Massachusetts company to settle charges that it (a) made unlicensed exports to Mexico of thermal imaging cameras controlled for national security and regional stability reasons and (b) failed to comply with recordkeeping requirements in connection with these exports by, among other things, failing to retain related invoices.

The company will also be required to hire an unaffiliated third-party consultant to complete an external audit of its export controls compliance program. This audit must cover the three-year period beginning March 5, 2014, and must be in substantial compliance with the export compliance program sample audit module. A final audit report will be due to BIS no later than June 5, 2018.

If the company fails to meet these requirements BIS may suspend its export privileges for one year.

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