The U.S. Government continues to enforce a variety of export compliance laws in an effort to thwart the movement of goods and services to Iran. This has resulted in substantial penalties for individuals and companies who attempt to circumvent these regulations.
Yesterday, for example, the BIS issued a Temporary Denial Order (TDO) against Delfin Group of North Charleston, South Carolina, and its president, Markos Baghdasarian, based on evidence that these parties are trying to violate the EAR and OFAC sanctions by diverting U.S. goods to Iran through the United Arab Emirates. Specifically, Delfin, Mr. Baghdasarian and a variety of related companies are suspected of illegally transshipping polymers, oil additives and aviation engine lubricating oils from the United States to Iran via the UAE.
According to the order from BIS, Delfin/Baghdasarian has been working with Naren Sachanandani and his company, Do-It FZC, as well as others, to ship these items to the UAE. Under the alleged scheme, the items are then re-packaged and re-labeled in the UAE for further transport to end users in Iran. U.S. Customs agents have already detained several such shipments prior to transshipment. The denial order makes it illegal for any of the named parties to participate in any transactions subject to the EAR. Furthermore, it makes it illegal for any person to engage in business with the denied parties for items or services subject to the EAR.
Yesterday’s TDO follows earlier actions by BIS along the same lines. Namely, the renewal of a denial order against Mahan Airways and the guilty plea of a former manager of a Netherlands-based freight forwarder for facilitating the illegal export of certain acrylic adhesives and spray paint coatings to Iran.
These enforcement actions underscore the need for U.S. companies to continue incorporating the necessary compliance procedures into their business practices – particularly when it comes to screening of all parties involved in export transactions. Simply put, no one can afford to ignore export compliance laws and risk penalties like these.
Looking for more information about import/export compliance? Be sure to visit our export law blog for the latest developments on ITAR, EAR and other regulatory requirements.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance. Follow Tom on Google+.