Background

Civil Penalty for Reexports to Syria

The Bureau of Industry and Security has issued an order imposing a $368,000 civil penalty against a Lebanese company for reexporting generator sets subject to the Export Administration Regulations to Syria without the required BIS licenses. BIS states that these items were assembled in Lebanon incorporating U.S.-origin engines and were subject to the EAR when reexported to Syria because they contained more than 10 percent of controlled U.S.-origin content.

Export Privileges Suspended for Unlicensed Shipments

The Bureau of Industry and Security has issued an order suspending for ten years the export privileges of an individual convicted of exporting gas turbine parts to Germany with knowledge that such goods were intended specifically for reexportation to Iran without the required U.S. government authorization. This individual was previously sentenced to a $5,000 fine and a $100 assessment.

As a result, until Aug. 14, 2029, neither this individual nor anyone acting on his behalf may directly or indirectly participate in any way in any transaction involving any commodity, software, or technology exported or to be exported from the U.S. that is subject to the Export Administration Regulations. BIS is also revoking all export licenses in which this individual had an interest at the time of his conviction.

For more information on export controls and compliance, please contact attorney Kristine Pirnia.

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