The Bureau of Industry and Security has imposed a $3.3 million civil penalty against a U.S. company for exporting to Russia transistors and related products that can be used for avionics or radar systems. BIS states that several of these shipments occurred after the affected products had been designated as common high priority list items (i.e., those that Russia specifically seeks to procure for its defense industrial base) and that all of them occurred without the requisite BIS license or other authorization.
BIS states that the company was aware that it was shipping goods to Russian end-users but was unaware that these goods required a license for export to Russia because its export compliance program lacked procedures requiring regular review of revisions to the Export Administration Regulations. Once the company realized its error it promptly stopped all shipments intended for Russian end-users, filed a voluntary self-disclosure with BIS, and cooperated extensively with the subsequent investigation by BIS’s Office of Export Enforcement.
BIS notes that this VSD resulted in a significant penalty reduction and that it will suspend $1.5 million of that penalty due to the company’s limited ability to pay.
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