Category: Violations

I’m something of a “news junkie.” If you’re like me, then you are constantly hearing about certain countries that can’t seem to keep themselves out of the news. You may even occasionally hear the name of a country that your company either does business with, or is contemplating as a customer. There are many ways...

The Greek philosopher Heraclitus once famously said: “The only thing that is constant is change.” In the world of trade compliance, country sanctions and restricted parties lists are no exception to this rule. Time and time again, I see people with printed lists of countries posted near their computers, to remind them of where they...

Exporters can anticipate “robust and comprehensive” enforcement efforts in the near future, according to remarks given by David Mills, Assistant Secretary for Export Enforcement. Mills was speaking at the annual update conference hosted by the U.S. Bureau of Industry and Security (BIS) in Washington, D.C. According to Secretary Mills, for fiscal year 2013, BIS investigations...

Earlier this month, Esterline Technologies Corporation agreed to pay a $20 million civil penalty for alleged violations of the International Traffic in Arms Regulations (ITAR). According to the State Department’s charging letter, these violations span a number of years, and cover various subsidiaries and departments within the company. Although the charges against the company are...

Wars are won and lost as a result of many factors. One factor that is often overlooked is the role that information plays in the outcome of any struggle. For example, the fake army commanded by General George S. Patton at Calais convinced the Axis powers that the Allies were going to take the shortest...

One of the myths I often hear from foreign companies is that they’re not subject to the jurisdiction of U.S. export control regulations. Like so many myths, I think some people believe that if they simply repeat this often enough, it will eventually become true. (Never mind that the file cabinets of U.S. export enforcement...

If there’s a silver lining in every cloud, then the recent ITAR penalties levied against Aeroflex, Inc. and its subsidiaries can hold some valuable lessons for other companies. On July 25, DDTC charged the microelectronics manufacturer with 158 violations of the AECA and ITAR. The alleged violations cover an extensive time period – more than...

Recently, a Washington-based manufacturer of printed circuit boards (PCBs) found out how costly it can be to ignore U.S. export regulations. Precision Image Corporation and its owner, Chih-Kwang Hwa, plead guilty to charges that it violated the ITAR. The company faces fines of up to $1 million and Hwa could be sentenced to as much...

Most of us have visited eBay to sell or buy an item. (After all, who wouldn’t want to bid on such things as an autographed air guitar or a handmade ghost detector?) However, if you’re going to sell an item on eBay, in addition to making sure there’s a market for your products, you better...

Here’s a recent enforcement case that underscores the importance of a robust restricted parties screening approach as part of your company’s export compliance policies. Last month, Alex Tsai and Gary Tsai – father and son, both from Taiwan – were arrested for allegedly attempting to export to North Korea a variety of machines which can...