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…
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…
Last week, DDTC released a proposed charging letter and subsequent consent agreement, alleging 125 charges of ITAR violations against Raytheon Company and its subsidiaries. The documents provide some interesting reading for export compliance officers and corporate counsel who are interested in avoiding similar ITAR compliance problems for their companies. Although the alleged Raytheon ITAR violations…
A former employee of L-3 Communications’ Space and Navigation Division was recently sentenced to 70 months in federal prison for exporting U.S. technology to China. Sixing Liu, 49, (aka “Steve Liu”) of Flanders, New Jersey, was convicted on nine counts, which range from lying to federal agents to six counts of International Traffic in Arms…
Recent stories here and here (and just about everywhere else) are pointing to an ongoing investigation, recently trumpeted by two Congressmen, which claims that NASA may have been involved in illegal exports of sensitive technologies to China. The basic allegations of the investigation are that individuals from NASA’s AMES Research Center conducted illegal transfers of…
A recent story in the Sarasota Herald-Tribune describes a raid conducted by law enforcement agents of a local warehouse owned by a multimillion-dollar package forwarding company named MyUS.com. The article provides few details on the raid, other than to say this is part of an active investigation related to “export enforcement.” It also quotes the…