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ofac-violations-epsilon

Exporting “with knowledge.” The case of Epsilon Electronics

We all know that OFAC can impose civil penalties against any person who exports goods to a third party, when that person has reason to believe the goods are destined for Iran. But how far does OFAC have to go to prove that the goods were actually reexported to Iran? A recent decision by the U.S. Court of Appeals sheds some light.

Former UTRC employee arrested for ITAR violations

Yu Long, a Chinese citizen and former employee of the United Technologies Research Center (UTRC) pleaded guilty to the export and the attempted export of defense articles from the U.S. in violation of the Arms Export Control Act. The maximum possible sentence Long can serve is 20 years.

Three individuals sentenced for export violations

On 20 December 2016, in the Federal District of Connecticut, JIANG YAN, 34, of Shenzhen China was sentenced to time served (12 months imprisonment) for attempting to purchase and export to China without a required export authorization for certain sophisticated integrated circuits used in military satellites and missiles. Additionally, for conspiring to sell counterfeits of those same integrated circuits to a purchaser in the United States. Yan was also ordered to forfeit $63,000 in cash seized incident to his arrest.

Wanted: Your voluntary disclosures

Traditionally Export Related Voluntary Disclosures/Voluntary Self-Disclosures have been filed with DDTC, BIS, OFAC or occasionally the Bureau of Census. Each of these agencies encourages companies and individuals to file the Disclosures and they provide an incentive in that the filing can be considered as a mitigating factor to the violation(s) committed.