An Australian man and his company have been charged with several counts of violating the EAR and ITAR (as well as OFAC trade embargoes). The charges point to an alleged scheme to export restricted items from the U.S. to Australia, for transshipment to Iran, in violation of numerous export control regulations.
According to the Department of Justice press release, David Levick and his company, ICM Components Inc., were involved in a number of attempts to procure a variety of items for an Iranian customer which otherwise would require a license for export from the United States. These items included:
- Vertical Miniature Gyroscopes (controlled as defense articles under the ITAR)
- Servo Actuators (also defense articles under ITAR)
- Precision Pressure Transducers (which have a variety of aerospace applications, presumably controlled by EAR and requires an OFAC license to Iran)
- Emergency Flotation System Kits (likely EAR)
- Shock Mounted Light Assemblies (for helicopters and fixed wing aircraft, also likely EAR)
Some of the activities Mr. Levick allegedly engaged in include: using a broker in Florida to place orders for goods to conceal their end-user, structuring payments to avoid restrictions on Iranian financial transactions, and concealing the country of ultimate destination for the items to a variety of U.S. manufacturers, distributors, shippers and freight forwarders.
If convicted, Mr. Levick faces a potential maximum of five years in prison for the alleged EAR and ITAR violations, plus 20 years in prison for each count of the Iran embargo, as well as a forfeiture of at least $199,227 (… and 41 cents).
Tom Reynolds is the President of Export Solutions, a consultancy firm which specializes in helping companies with import/export compliance.