Background

The Bureau of Industry and Security has issued an order imposing an $8,500 penalty against a U.S. company for exporting camera accessories to Iran via the United Arab Emirates without the required U.S. government authorization. If the company does not make full and timely payment of this penalty, BIS may suspend its export privileges for one year.

The items at issue are subject to the Iranian Transactions and Sanctions Regulations, which, absent prior authorization by the Office of Foreign Assets Control, prohibit the direct or indirect exportation, reexportation, sale, or supply of any goods, technology, or services to Iran, including shipments to a third country that are intended for supply, transshipment, or reexportation to Iran. However, BIS states, the company sent its customer and freight forwarder a letter stating erroneously that the items could ship “no license required.”

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