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What’s scarier than Halloween Kills? What might send shivers down your spine faster than a ghoulish costume? If your answer wasn’t “submitting a license”, then we might have something to learn from you! But if the idea of submitting an export license feels scary, then we might have a solution.

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.

Recently the former CEO of Stargate Apparel, Inc. and Rivstar Apparel, Inc., ran afoul of 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.

Recently there have been an increased number of enforcement cases from BIS, OFAC, and DDTC 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 actions.