The Bureau of Industry and Security has imposed a $140,000 civil penalty against a U.S. company to settle charges that it exported crime control items to Colombia, Guatemala, Mexico, Nigeria, Pakistan, Panama, Trinidad & Tobago, and Uruguay without the required BIS licenses.
BIS states that the company did not have an export control compliance program in place despite approximately a decade of experience as an exporter, lacked procedures to determine the export classification of the products it sold and the licensing requirements for exports to its foreign customers, and failed to retain required records such as bills of lading, air waybills, and correspondence with freight forwarders and foreign customers. Further, in interviews with BIS enforcement officials, the company’s managing director demonstrated unfamiliarity with basic export control concepts and practices, including asserting that he had no knowledge of the U.S. government’s lists of restricted persons or the Export Administration Regulations.
BIS is suspending $130,000 of the penalty for two years and will waive it thereafter provided the company commits no further export violations during that time.
For more information on export compliance, please contact attorney Kristine Pirnia via email.
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