Background

The Bureau of Industry and Security announced recently an administrative settlement of $439,992 against a U.S. company for (1) submitting a back-dated document to make it appear that a transaction complied with the Export Administration Regulations and (2) exporting military aircraft parts to entities in Malaysia and South Korea without the required BIS license or authorization.  

According to an agency press release, BIS identified the false document after requesting a copy of a prior consignee statement that exporters are required to obtain prior to utilizing license exception STA (strategic trade authorization). The company had not obtained the required statement but instead of admitting that mistake advised its overseas customer to back-date the PCS.

As part of the settlement the company must provide export compliance training on the EAR to its relevant employees and has agreed to a one-year probationary period. It will also have $364,992 of the penalty amount suspended due to its financial condition, an amount that will be waived after the one-year probationary period if the company complies with all provisions of the settlement.

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