Background

The Bureau of Industry and Security has issued an order imposing a $685,051 penalty against a company to settle charges that it exported items subject to the Export Administration Regulations to an end-user in Iran without the required authorization. BIS notes that the items at issue are categorized as EAR99 but required authorization for export to Iran. According to the charges, the company knew the items were destined to Iran in violation of U.S. export controls and took deliberate actions to conceal that fact and its unlawful conduct from regulators.

In addition to the penalty, the company will be required to complete three annual export compliance audits and report the results to BIS and to ensure the completion of export compliance training by all employees within a year. BIS also denied the company’s export privileges for three years but suspended that action provided the company meets certain requirements.

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