Have you ever struggled to determine the responsibilities and parties in a routed export transaction? If so, you’re not alone! Routed transactions make even the most experienced exporters pause. They have been described as dreaded, confusing, mysterious and complicated!
Earlier this month, DDTC published a new Consent Agreement with Bright Lights USA, Inc. of Barrington, New Jersey. This agreement alleges a variety of different ITAR violations, including technical data exports and failure to keep adequate records.
We all know that OFAC can impose civil penalties against any person who exports goods to a third party, when that person has reason to believe the goods are destined for Iran. But how far does OFAC have to go to prove that the goods were actually reexported to Iran? A recent decision by the U.S. Court of Appeals sheds some light.
We get a lot of questions about exporting titanium products and other metals from the United States. Recently, I sat down with one of our clients – Performance Titanium Group (PTG) – to discuss some of the basic “do’s and dont’s” when exporting titanium.
Zhongxing Telecommunications Equipment Corporations, (“ZTE”), and its subsidiaries and affiliates entered into a settlement with three U.S. government agencies covering civil and criminal charges filed against the company. This represents a new record for EAR enforcement penalties.
Access USA will pay millions for export violations. The company admits to numerous EAR violations.
During the dark days of winter (January to be exact), the U.S. Department of Commerce, Bureau of Industry and Security (BIS), published a new regulatory requirement dealing with items controlled under multilateral regimes.
On 20 December 2016, in the Federal District of Connecticut, JIANG YAN, 34, of Shenzhen China was sentenced to time served (12 months imprisonment) for attempting to purchase and export to China without a required export authorization for certain sophisticated integrated circuits used in military satellites and missiles. Additionally, for conspiring to sell counterfeits of those same integrated circuits to a purchaser in the United States. Yan was also ordered to forfeit $63,000 in cash seized incident to his arrest.
Yu Long, a Chinese citizen and former employee of the United Technologies Research Center (UTRC) pleaded guilty to the export and the attempted export of defense articles from the U.S. in violation of the Arms Export Control Act. The maximum possible sentence Long can serve is 20 years.
DDTC has released its first summary report from the re-initiated Company Visit Program. Is your company following these best practices and recommendations?