The Bureau of Industry and Security has announced an administrative settlement with a U.S. company charged with unlicensed exports of EAR99 items to Huawei Technologies Co. Ltd. and two subsidiaries after they were designated on the Entity List in May 2019.
The company self-reported that the violations occurred pursuant to errors in its export screening process and has since instituted new screening and compliance procedures for all orders. BIS states that these actions were factored into its penalty decision.
The company will pay a civil penalty of $80,000 as part of the settlement. It will also complete annual third-party audits of its compliance system for the next two years and submit the results to BIS. If those audits identify actual or potential export violations the company will have to promptly provide a detailed plan of corrective actions to be taken along with copies of the pertinent air waybills and other export control documents and supporting documentation related to the identified compliance concerns.
For more information on ensuring export compliance for your business, please contact attorney Kristine Pirnia via email.
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