Category: 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. Long, who was a legal resident in...

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. The number of agencies...

In March of 1983, during a speech in Orlando, Florida, former President Ronald Reagan first used the phrase the “evil empire” to describe the Soviet Union. The phrase stuck, and a new era of emphasis on Export Regulations and Controls began. Stopping the USSR from acquiring U.S. technologies that could be used against us or...

Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine): "Export-controlled technical data has a unique set of rules designed to ensure that it is not inadvertently released or “exported” to foreign persons either inside or outside the United States. As...

The U.S. Bureau of Industry and Security (“BIS”) recently issued administrative settlement documents against a company called Fulfill Your Packages ("FYP"). Under the settlement agreement, FYP agreed to pay a $250,000 fine, of which $190,000 was suspended on the condition that the company has no export violations over the next two years. According to the...

For any industry, the “cost of doing business” inevitably increases over time. For companies engaged in ITAR-controlled work, the cost of not doing business compliantly is about to skyrocket. DDTC has announced that, effective August 1, 2016, the maximum amount that can be levied as a Civil Monetary Penalty will change. Most notably, for each...

A Florida woman, Amin Yu (a/k/a Yu Amin, a/k/a Amy Yu) was charged in a superseding indictment with conspiring to illegally export U.S. technology to a Chinese state-owned entity. This technology is used in underwater drones. Among other charges in the indictment (including illegal exports, money laundering, and acting as an agent for a foreign...

How do you build a “culture of trade compliance” in your organization? You might as well ask, “How do you eat an elephant?” In both cases, the answer is seemingly simple, yet also complex – one bite at a time. A quick search for “culture of compliance” on the internet yields thousands of scholarly and...

Chinese national Fuyi “Frank” Sun has been arrested in connection with a plot to illegally export high-grade carbon fiber from the United States to China. Sun was arrested while traveling to New York to close a deal with a distributor of the fiber which is typically used for aerospace and military purposes. Turns out the...

A Singapore man, Lim Yong Nam (aka Steven Lim) was extradited to the U.S. from Indonesia (where he’d been detained since October 2014) to face charges stemming from his alleged role in a conspiracy to illegally export radio frequency modules to Iran. According to the U.S. Government, some of these modules ended up being used...