The Bureau of Industry and Security has imposed a $25,000 civil penalty against a company in the United Arab Emirates to settle charges that it committed two violations of the Export Administration Regulations.

According to BIS, powder-grade nickel is classified under ECCN 1C240 and controlled for nonproliferation and antiterrorism reasons and thus required a license to be exported to the UAE. The company represented on an export license application that it would be using this product to manufacture self-lubricating seal rings in the UAE for distribution in the UAE and would not reexport them without BIS authorization. However, during a post-shipment verification the company’s director said the company had intended to export the manufactured rings to an Azerbaijani company.

BIS is suspending half of the penalty for two years and will waive it thereafter if the company commits no further export violations. If the company fails to pay the penalty or otherwise fully comply with this settlement agreement, BIS may deny its export privileges for two years.

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

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