Background

The Bureau of Industry and Security has assessed a $51,921 civil penalty against a German company to settle charges that it transshipped controlled items to Iran through Germany for the benefit of a restricted entity. BIS is also denying the company’s export privileges for three years but is suspending that denial provided the company pays the penalty and does not commit any further export violations during that time.

The items at issue were designated as EAR99 under the Export Administration Regulations, which is a designation for items subject to the EAR but not listed on the Commerce Control List. They were also subject to the Iranian Transactions Regulations, which prohibit exports and reexports of EAR99 items that are also subject to the ITR without prior authorization from the Office of Foreign Assets Control.

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