Background

The Bureau of Industry and Security has reached a settlement with a U.S. company that will pay a $1.6 million civil penalty to settle charges that it violated the Export Administration Regulations in connection with unlicensed exports to Russia. BIS said the company filed a voluntary self-disclosure of the subject transactions and has made investment in and improvement of its existing compliance program.

According to the settlement agreement, the company exported refiner plates to a foreign company that subsequently reexported them to Russia. While these plates are classified EAR99, at the time of export they were classified under HTSUS numbers that required a license for export to Russia, and the sales to Russia were conducted without the requisite BIS license or other authorization.

BIS noted that refiner plates are used in the refining process of machines used to make paper pulp, which is a basic component of manufacturing paper. “While there is no evidence that [the] … refiner plates were designed for, used, or could be used, for military-related purposes,” BIS said, “wood and flax pulp could potentially have military application.”

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