Two subsidiaries of Schlumberger Limited – one current and one former – were hit with sanctions violations in dual press releases this week. The combined fines totaled more than $1.5 million. According to the Treasury Department’s Office of Foreign Assets Control (OFAC), Cameron International Corporation provided oil and gas services to the Russian energy firm…
This past month we have seen multiple penalties handed down for illegal exports to prohibited destinations through the use of front companies and diversion. In three particular cases, the items were diverted to an end-user that was not originally disclosed and were shipped through an intermediary. Here is a brief overview of three recent cases…
We all remember the cute nursery rhyme “Peter Piper.” (Try reciting it five times fast!) But in today’s world of ransomware attacks, many U.S. companies are caught in a troublesome “pickle” trying to figure out what to do. Here’s the scenario. Over a weekend (particularly holiday weekends), your company may find itself hit by a…
Recently the former CEO of Stargate Apparel, Inc. and Rivstar Apparel, Inc., ran afoul of U.S. Customs and Border Protection (“CBP”) for Customs fraud due to the under-valuation of apparel imported into the United States from China. A former employee turned whistleblower filed a ‘qui tami’ whistleblower complaint under the False Claims Act. The former…
On August 9, 2021, Keysight Technologies (“Keysight”) agreed to a settlement with the Directorate of Defense Trade Controls (“DDTC”) on the allegations of committing twenty-four (24) export violations of the International Traffic in Arms Regulations (“ITAR”) for unauthorized exports of technical data and software to multiple countries that would have required licenses. Based on the…
Recently there have been an increased number of enforcement cases from the Bureau of Industry and Security (“BIS”), Office of Foreign Asset Controls (“OFAC”), and Directorate of Defense Trade Controls hitting the compliance newsletter circuit and we thought it worthwhile to outline the issues for our readership and note some key takeaways from the agency’s…
Recently, Yi-Chi Shih, of Hollywood Hills, CA was sentenced to more than five years in prison for scheming to illegally export integrated circuits with a military end-use to China. In addition, he was also ordered to pay a fine of $362,968 for restitution and $300,000 to the IRS. Aside from these convictions, Y-Chi Shih was…
On April 30,2021, FLIR Systems, Inc., agreed to a settlement of $307,922 with the Department of Commerce on what are being called egregious violations of the Export Administration Regulations (EAR), Section 764.2.g. The Department of Commerce settlement alleges FLIR, between November 2012 and December 2013, made “inaccurate or incomplete representations, statements, or certifications to the…
On April 27, 2021, the Directorate of Defense Trade Control (DDTC) released the contents of the latest Consent Agreement imposed on Honeywell International, Inc., who agreed to the settlement of the civil penalty of $13M for thirty-four (34) violations of the International Traffic in Arms Regulations specific to the unauthorized export or retransfer of technical…
Unlicensed Exports Apply To All Foreign National Students It’s been several years since the imprisonment of John Reece Roth, a former University of Tennessee electrical engineering professor who was convicted of conspiracy, wire fraud and fifteen (15) violations of exporting ITAR controlled defense articles. Professor Roth was involved in a U.S. Air Force contract for…