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…
Earlier this month, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) denied export privileges for two individuals and three companies. The actions center around a conspiracy to illegally export web-monitoring and controlling equipment and software to Syria. In particular, this conspiracy involved the Syrian Telecommunications Establishment (STE). “The settlement announced today results…
Recently, a South Carolina company, STREIT USA, was fined $3.5 million to settle charges related to the sale of U.S.-origin vehicles to end-users located in multiple countries. The company is part of STREIT Group, which is a global manufacturer of armored vehicles for military, security, luxury and other markets. As part of the settlement, $1.5…
Last week, oil and gas giant Schlumberger plead guilty to facilitating trade with Iran and Sudan, in violation of U.S. sanctions. The parent company’s Schlumberger Oilfield Holdings Ltd. (SOHL), which is a wholly-owned subsidiary of Schlumberger Ltd., agreed to a guilty plea for conspiring to violate the International Emergency Economic Powers Act (IEEPA) by willfully…
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…
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…
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…