The Bureau of Industry and Security has issued an order denying for 180 days the export privileges of three individuals and four companies located in Cyprus, Latvia, Tajikistan, and Russia. In addition, one of the individuals has been charged in U.S. federal court with violations of the Export Control Reform Act, smuggling goods from the U.S., and related conspiracy charges.

The three individuals are Russian nationals believed to have used three of the companies as pass-throughs to supply large amounts of U.S.-made, export-controlled items to the fourth company, a Russia-based supplier of dual-use electronics components to the Russian military in violation of the Export Administration Regulations. BIS’ Office of Export Enforcement detailed three prohibited export transactions in particular, noting that no license was sought or obtained in connection with these transactions and that the respondents concealed the intended use, end-user, and destination of the items from U.S. distributors.

BIS has determined that further export violations by the respondents are imminent in both time and degree of likelihood given the deliberate, covert, and determined nature of the misconduct and clear disregard for complying with U.S. export control laws. BIS is therefore issuing a temporary denial order to give notice to persons and companies in the U.S. and abroad that they should cease dealing with the respondents in export or reexport transactions involving items subject to the EAR.

Under this order, neither the respondents nor anyone acting on their behalf may directly or indirectly participate in any way in any transaction involving any commodity, software, or technology exported or to be exported from the U.S. that is subject to the EAR.

For more information on export restrictions and ensuring your company is in compliance, please contact attorney Kristine Pirnia via email.

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