Background

The Bureau of Industry and Security has assessed a $60,000 penalty against a Dutch company for deceptively shipping controlled items to Iran. The BIS also suspended the company’s export privileges for two years but then waived that suspension provided the company commits no further export violations during that time.

BIS states that after the company procured extruded butyl sealants (which are subject to the Export Administration Regulations) from a U.S. supplier for a customer in Iran, its freight forwarder returned the shipment to the supplier, citing U.S. sanctions prohibiting direct or indirect exports to Iran. The company subsequently provided its supplier with new invoices that listed a recipient in the United Arab Emirates and removed all references to Iran. Following that export, the company attempted to make another such shipment, but it was stopped by BIS prior to leaving the U.S.

For more information on export compliance, please contact attorney Kristine Pirnia via email.

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