import export violations

In December 1994, Digital Creations Corporation had plead guilty to charges that it illegally exported DEC computer equipment to the People’s Republic of China without first having obtained the required export license from the Commerce Department. BIS is responsible for implementing and enforcing the EAR, which regulate the export, reexport, and transfer (in-country) of items with commercial uses that can also be used in conventional arms, weapons of mass destruction, terrorist activities, or human rights abuses, and less sensitive military items. According to the superseding indictment, the defendants exported controlled U.S. aircraft parts from the U.S. to Monarch and Jungda in Singapore and Malaysia and then re-exported those items to companies in Tehran, Iran, without obtaining the required U.S. government licenses. The penalty was high in part because OFAC determined that senior management had known about the conduct that led to the violations, though it did not reach the $1.3 billion potential maximum, and in part because ING bolstered its compliance program in response to the violations. On March 23, 1998, the Commerce Department imposed a 10-year denial of export privileges pursuant to Section 11(h) of the EAA. Proclad pleaded guilty to one count of attempted export without an export license on Nov. 30, 2007 after being charged via information on Oct. 16, 2007. He potentially faces up to 20 years in prison and a million dollar fine if convicted. Special Agents from the Commerce Department’s Office of Export Enforcement Chicago Field Office investigated the case. WILLIAM CHAI-WAI TSU / DIMIGIT SCIENCE & TECHNOLOGY CO. LTD / CHEERWAY, INC. On Aug. 3, 2009, William Chai-Wai Tsu, an employee of a Beijing-based military contracting company called Dimigit Science & Technology Co. Ltd, and the vice president of a Hacienda Heights, CA, front company called Cheerway, Inc., was sentenced in the Central District of California to 40 months in prison. April, 2015. The investigation was conducted by the FBI. III. This investigation was conducted by ICE and DCIS. The investigation was conducted by ICE and DCIS. The civil penalty was based on a finding that on four occasions, Immediate Customs Service engaged in export transactions with a person whose U.S. export privileges had been denied. On June 21, 1999, the Commerce Department imposed a $30,000 civil penalty on Sun Microsystems of California, Ltd., a Hong Kong company, to settle allegations that it violated the EAR by arranging for shipments of computers to the People’s Republic of China (PRC) that did not adhere to a condition of the export license. These activities encompassed both civilian spacecraft and ballistic missiles. According to the charges, the defendants attempted to illegally export military cable assemblies, wiring harnesses and other restricted components to Canada in 2006 and 2007. The camera is capable of locating objects in day, night or adverse weather conditions, because of its ability to detect radiating heat. Potassium fluoride is controlled for export by multilateral agreement with the 30-nation Australia Group because, in addition to its legitimate commercial uses, the chemical has the potential to serve as a precursor in a chemical weapons program. The violations occurred in February 2003 when Ghashim and his company KZ Results exported computers and related equipment to Syria without the required licenses. On Feb. 5, 2009, two German nationals and a German company were indicted in the District of Massachusetts for conspiring to illegally export pump parts worth more than $200,000 to Iran in violation of the International Emergency Economic Powers Act. On Nov. 30, 2007, Murray Rinzler and his company World Electronics, Inc, were sentenced in the District of Connecticut to a criminal fine of $20,000 after pleading guilty on March 26, 2007 to charges that they conspired to violate the Arms Export Control Act by sending F-14 fighter jet components and other military items to Germany. Found inside – Page 21If the firm's export operations are satisfactory during that period payment of ... on the above import - export firm for several violations of the export ... On March 10, 2008, Seyed Maghloubi was sentenced to three years and five months in prison in the Central District of California to attempting to illegally export goods to Iran. On Oct. 18, 2010, a federal jury in the District of Maryland convicted Balraj Naidu, a citizen of Singapore, of conspiracy to provide material support to a foreign terrorist organization stemming from his efforts to supply the Liberation Tigers of Tamil Eelam (Tamil Tigers) with advanced American weaponry. The described violations relate to software controlled under Category XI(d) “due diligence” in scrutinizing the export control practices of any companies that they plan to acquire. December 2016. In the Washington case, Teledyne Industries, Inc. was assessed a $5,498,125 criminal fine for violations relating to zirconium exports that were supposedly destined for Greece, but which actually were rerouted to another destination. Ltd (—JungdaII), a Singapore-based successor to Monarch, was returned on May 22, 2008. The penalty settles allegations that the company illegally exported ATJ grade graphite to various foreign countries over a period of two years. As an exporter or importer, you should check all customers, exporters, and business partners against the OFAC list to avoid sanctions violations. A U.S. district court has dismissed a case challenging the different levels of liability for export violations that attach to companies and individuals. Operating through a Pennsylvania company called Saamen Company, the defendants allegedly illegally exported computers, fuel cell systems, ultrasonic liquid processors, ultrasound machines, and other laboratory equipment. The agreements will be reinforced by a new export control program implemented by the Departments of Commerce and Energy. On July 3, 2008, Keshari, Kesh Air International, as well as Bujduveanu, and his company Orion Aviation, were indicted for their participation in a conspiracy to export U.S.-made military and dual-use aircraft parts to Iran. The goods were routed to Iran through the Netherlands, the United Arab Emirates, and Cyprus. On Jan. 22, 2008, Green Supply, Inc., was sentenced in the Eastern District of Missouri to two years probation, a $17,500 fine and an $800 special assessment after pleading guilty in Nov. 2007 to export control violations involving the illegal export of controlled night vision systems. Ames is serving time in federal prison. The United States Government maintains a comprehensive economic sanctions program against the Government of Iran, which prohibits virtually all commercial transactions involving U.S.-origin goods or U.S. persons, or both, with the Government of Iran, unless specifically authorized. Questions concerning the DEA-236 form may be directed to DRI at telephone number 571-362-8355. This resulted in a $100,000 criminal fine and five years’ probation. May, 2013. However, the only types of products that can be declared as IFE . The Bureau of Industry and Security (BIS) alleged that on five occasions in 1998, Thompson/Center Arms Co., Inc. exported rifle and pistol scopes to Argentina, the Czech Republic, and Switzerland without the export licenses required by the Export Administration Regulations. December 2019. On two occasions, Knapp illegally exported items, including anti-gravity flight suits, to Hungary believing they were destined for Iran. Komoroski, of Nanticoke, Pa.; Korznikov, of Moscow, and two companies, D&R Sports Center and Tactica Limited, were charged in a 2008 superseding indictment with conspiring to smuggle military equipment, including rifle scopes, magazines for firearms, face shields, and other military equipment from the United States to Russian to be resold to unknown persons. On July 17, 1997, I.G.G. The Commerce Department’s New York office of Export Enforcement investigated the case. His export privileges have therefore been denied until October, 2019. After a six-week trial, 64-year old Yi-Chi Shih was found guilty of conspiracy to violate the International Emergency Economic Powers Act (IEEPA). was assessed a $50,000 criminal fine, a special assessment of $200 and placed on probation for five years. OFAC Violations. The case was investigated by the Commerce Department’s Office of Export Enforcement field office in New York and the U.S. Customs Service, Philadelphia, PA. On June 17, 1997, Lansing Technologies Corporation (Lansing Technologies), represented by its president, Red-Chin Yang, pleaded guilty in the U.S. District Court for the Eastern District of New York to exporting a vector computer processor and a data acquisition control system to the People’s Republic of China without obtaining the required export licenses from the Department of Commerce. The transaction with Iran was allegedly arranged through the Iran Aircraft Manufacturing Industrial Company, known as HESA, which has been designated by the United States as an entity involved weapons mass destruction proliferation. It was also alleged that, in October 1992, NWT attempted to illegally export a MIPS computer to the same destination in the People’s Republic of China. As your company's import or export compliance counsel, we will ensure that you have the policies, procedures, protocols, and documentation you need to . On March 9, 2010, Uni-Arab Engineering and Oil Field Services, a firm incorporated in the United Arab Emirates and operated in part by two naturalized U.S. citizens, Jaime Radi Mustafa and Nureddin Shariff Sehweil, pleaded guilty in the Eastern District of Louisiana to violating U.S. sanctions against Libya. Thus, “[a]s a general principal, . Shu provided the PRC with assistance in the design and development of a cryogenic fueling system for space launch vehicles to be used at the heavy payload launch facility located in the southern island province of Hainan, PRC. During the conspiracy, which spanned from April 2005 to March 2007, Myles supplied a number of military aviation parts, including F-14 parts, to an Iranian national, who allegedly picked up the parts in Dubai, United Arab Emirates and Bangkok, Thailand. This accelerometer has military applications in — smart bombs and missile development and in calibrating the g-forces of nuclear and chemical explosions. Kan Chen, was sentenced to 30 months imprisonment and three years supervised release for conspiring to violate the Arms Export Control Act (AECA) and International Traffic in Arms Regulations (ITAR); attempting to violate the AECA and ITAR; and violating the International Emergency Economic Powers Act. According to court documents, Chen caused or attempted to cause the illegal export of over 180 export-controlled items, valued at more than $275,000, from the United States to China. March 2012. The penalty settled allegations that the company exported U.S.-origin ultraviolet fire detection systems to India on two occasions between November and December 1998, without the required Department of Commerce export licenses. The investigation was conducted by ICE and CBP.`. The Commerce Department alleged that between May 1998 and August 1998, Refinery Industries, Inc., attempted to export illegally gas detection equipment to Iran. As a result of the Dallas Field Office’s investigation, the criminal information filed in the Galveston, Texas, division of the U.S. District Court for the Southern District of Texas, alleged that NWT had exported three Sun Microsystems computers to a nuclear equipment factory located in the People’s Republic of China in August 1992, without the required validated export license. L. 114–125, set out as a note under section 211 of Title 6, Domestic Security. FLOYD D. STILWELL / MARSH AVIATION COMPANY. The following are a number of examples of how enforcement officials discover export violations: Disgruntled Employees. The Bureau of Industry and Security (BIS) reported that Phillip Andro Jamison had been found guilty of exporting a weapon sighting device to the U.K without a license. In this case, the violation of OFAC sanctions was found to be willful and with knowledge of the illegal nature of the transactions involved. Sogda allegedly sent several shipments of goods through Iran without the requisite licenses. [8] These are the Arms Export Control Act (22 USC Chapter 39 (§§2751-2799aa-2)), the statutory authority for the International Traffic In Arms Regulations, and the International Emergency Economic Powers Act (50 USC §§ 1701-1707), the statutory authority for the Export Administration Regulations and many of the U.S. Sanctions Programs. BNP Paribas SA agreed to pay $963,619,900 to settle apparent violations of OFAC regulations involving multiple financial transfers to the Sudan, Iran, Burma, and Cuba, over the span of several years. On March 12, 2009, a federal grand jury in the District of Columbia returned an indictment charging Yaming Nina Qi Hanson, her husband Harold Dewitt Hanson (an employee at Walter Reed Army Medical Center), and a Maryland company, Arc International, LLC, with illegally exporting miniature Unmanned Aerial Vehicle (UAV) Autopilots to a company in the People’s Republic of China. February, 2014. The investigation was conducted by BIS and ICE. Importers of all FIFRA-regulated pesticides and devices (including unregistered pesticides) must comply with the U.S. Customs and Border Protection (CBP) regulations set forth at 19 C.F.R. In settlement of administrative charges, on January 24, 2002, BXA’s Assistant Secretary for Export Enforcement imposed a $1.12 million civil penalty on Thane-Coat, Inc. Thane-Coat’s export privileges, as well as those of the company’s president, Jerry Vernon Ford, and its vice-president, Preston John Engebretson, also were denied for a period of 25 years. On July 17, 2008, Cryostar SAS, formerly known as Cryostar France, a corporation headquartered in France, was sentenced in the District of Columbia to a criminal fine of $500,000 and corporate probation of two years. For example, any import alert that starts with a . On February 1, 1999, the Commerce Department imposed a $12,000 civil penalty on Fritz Companies, Inc. to settle allegations that its Houston, Texas office, furnished information regarding another person’s business relationships with or in a boycotted country by certifying that the goods shipped were not of Israeli origin, were not shipped from Israel, and did not contain any material from Israel. On February 2, 1998, the Judge sentenced Fernandez to five months’ imprisonment, two years’ supervised release, five months of which must be spent in home detention and imposed a special assessment of $250. This is frequently referred to as a “litigation hold notice,” “preservation letter” or “stop destruction request.”. Twenty-two million dollars ($22,000,000) of this civil penalty will be suspended as set forth in paragraph (17)(b) of the Consent Agreement on the condition that Meggitt applies this amount to self-initiated, pre-Consent Agreement remedial compliance measures. § 2751 et seq., and the International Traffic in Arms Regulations (ITAR), 22 C.F.R. JAMES ANGEHR / JOHN FOWLER / ENGINEERING DYNAMICS, INC. On Aug. 7, 2008, James Angehr and John Fowler, the owners of Engineering Dynamics, Inc. were sentenced to five years probation, fined $250,000 and ordered to forfeit $218, 583. Two subsidiaries of Halliburton Energy Services, Inc. allegedly committed the violations by dealing in property in which Cuba had an interest when they exported goods and services, totaling $1,189,752, in support of oil and gas exploration and drilling activities within Angola’s Cabinda Onshore South Block oil concession. Because the exercising of the foreign affairs function, including the decisions required to implement the Arms Export Control Act, is highly discretionary, it is excluded from review under the Administrative Procedure Act.”, “This part does not confer any procedural rights or impose any requirements based on the Administrative Procedure Act for proceedings charging violations under the EAA, except as expressly provided for in this part.”. The Department also alleged that RMI Titanium made false and misleading statements of material fact on export control documents. Countering America’s Adversaries Through Sanctions Act, Export Classification and Trade Data Management, International Traffic in Arms Regulations (ITAR), Deemed and Hand-Carried Export Compliance Risk Manager, BIS Export Administration Regulations (EAR). On June 16, 1997, the Commerce Department imposed a $50,000 civil penalty on Delft Instruments, N.V., a firm located in the Netherlands, to settle allegations that Delft made false statements to the Department in connection with an enforcement action. David Chan, owner of Well Complex International, pled guilty to charges that he violated the false statement statute in connection with the illegal exportation of hafnium granules to the People’s Republic of China. WaveLab pleaded guilty on March 7, 2008 to a criminal information filed the same day. Spitz pleaded guilty to count one of the indictment in the case on Sept. 12, 2008. The Department alleged that on three occasions, the Chelsea, Massachusetts, office of Hellmann prepared and used export control documents to ship titanium bars from the United States to Sweden, representing that the exports qualified for export under general license G-DEST, when in fact a validated license was required. As part of the settlement, $40,000 of the civil penalty and the denial of export privileges will be suspended and then waived provided that Helco does not violate U.S. export control laws during the suspension period. Life Technologies voluntarily disclosed the violations to the Department and cooperated fully in the investigation. Food Partner Network News. Bujduveanu was arrested at his Plantation, Florida, home on June 21, 2008. Taipan Enterprises was ordered to pay a fine of $15,000. The company now faces a potential fine of up to $1,000,000, while Oertmann could receive a prison term of up to ten years if found guilty. On February 1, the U.S. Commerce Department, Bureau of Industry & Security (BIS), announced a settlement (available here) with Princeton University in connection with 37 alleged violations of the Export Administration Regulations (EAR). © 2021 Williams Mullen All Rights Reserved. FRANCISCO FERREIRO-PARGA/ CARLOS FERNANDEZ/KENNETH BRODER/MANUEL TORRES/PEDRO BORGES. [11] The court stated: “Under the standard of willfulness described above, [the defendant’s] true belief as to the illegality of transporting the [article subject to control] is sufficient to establish culpability under the AECA even if unaccompanied by knowledge of the contents of the USML.”  Id. The Department also alleged that Data General made a false statement on an export control document related to the shipment of computer equipment to Mexico. In such action, the validity, amount, and appropriateness of such penalty shall not be subject to review. Her co-defendant, Alireza Jalali, had previously plead guilty in November 2017. Found inside – Page 36Inspection staff developed a wildlife import/export reference manual for the ... Brownsville, Texas: Violations detected at this port of entry primarily ... On June 14, 2007, Tak Components pleaded guilty to 16 counts of violating the International Emergency Economic Powers Act. Fernandez pled guilty to charges that he violated the Trading with the Enemy Act and the federal criminal conspiracy statute. The criminal fines provided for in this section are exempt from the provisions of, {'misc': '', 'cleanpath': '/uscode/text/13/305', 'headtext': ' Penalties for unlawful export information activities', 'cfr_titles': [{'title': '15', 'parts': [{'part': '30', 'cleanpath': '/cfr/text/15/part-30', 'headtext': 'FOREIGN TRADE REGULATIONS'}]}, {'title': '39', 'parts': [{'part': '20', 'cleanpath': '/cfr/text/39/part-20', 'headtext': 'INTERNATIONAL POSTAL SERVICE'}, {'part': '111', 'cleanpath': '/cfr/text/39/part-111', 'headtext': 'GENERAL INFORMATION ON POSTAL SERVICE'}]}], 'section': '305'}, Failure to file; submission of false or misleading information.—, Any person who is convicted under this subsection shall, in addition to any other penalty, be subject to forfeiting to the United States—, The Secretary may remit or mitigate any penalties imposed under paragraph (1) if, in the Secretary’s opinion—, Deposit of payments in general fund of the treasury.—, Pub. HENRY JOSEPH TROJACK/HAMID ABDOL RASHIDIAN. TAL entered a plea of nolo contendere to a felony violation of the Export Administration Act for making false and misleading statements in connection with an application submitted by the McDonnell Douglas Corporation (MDC) and CATIC for a license to export machine tools to the PRC. The appeal was based upon violations of the APA and constitutional protections. Huang was charged in 2006 with operating as a representative for the Chinese Electronic System Engineering Corporation, the technology procurement arm of the government of China. Thus, a transaction undertaken by a London-based subsidiary with a Cayman firm was sufficient for OFAC to find an American firm apparently in violation of sanctions against dealing with Iran. The case was the result of a joint investigation by the Commerce Department’s Office of Export Enforcement field office in New York and the U.S. Customs Service. On February 26, 1997, the Commerce Department imposed a $5,000 civil penalty on Morrison Express Corporation, of Chelsea, Massachusetts, for allegedly preparing a shipping document that contained false information. The case was conducted by BIS. The Bureau of Industry and Security (BIS) reported that Xun Wang was convicted of trying to export epoxy coatings to a nuclear reactor in Pakistan without the appropriate licenses. The defendants also falsely listed Monarch and Jungda as the ultimate recipients of the parts on export documents filed with the U.S. government. Relief Found. If any person fails to pay a civil penalty imposed under this chapter, the Secretary may request the Attorney General to commence a civil action in an appropriate district court of the United States to recover the amount imposed (plus interest at currently prevailing rates from the date of the final order). On November 14, 2001, the Department of Commerce imposed a $2.12 million civil penalty against McDonnell Douglas Corporation of St. Louis, Missouri, as part of a settlement of charges that the company violated federal export control laws. The conviction resulted from a joint investigation by the Office of Export Enforcement’s Dallas field office and the U.S. Customs Service, Houston, Texas. The Department’s Bureau of Export Administration (BXA) had alleged that Cohen had concealed an illegal transfer of an infrared camera from BXA agents. On July 17, 2008, in the Central District of California, Air Shunt Instruments, Inc., was sentenced to pay a criminal fine of $250,000 and a special assessment of $400 for making false statements on Shipper’s Export Declaration in claiming that a military gyroscope being sent overseas in 2003 did not require an export license, when in fact the item required such a license. Incorrectly following export procedures can lead to large expenses, loss of export privileges, and even prison time for criminal penalties. The goods were exported to Bharat Heavy Electrical Limited, an organization on the Entity List. The investigation was conducted by the FBI and ICE. The company agreed to pay a criminal fine of $414,000 and a $400 special assessment. The defendants were indicted on June 24, 2008 for illegally exporting military night vision systems. November, 2013: The Bureau of Industry and Security announced Weatherford International Ltd. in Houston, Texas, and four of its subsidiaries (collectively, “Weatherford”) have agreed to pay a $50 million civil penalty following allegations that they exported oil and gas equipment to Iran, Syria and Cuba in violation of the Export Administration Regulations (EAR) and the Iranian Transactions and Sanctions Regulations (ITSR). I'm trying to import this data into an empty copy (created with generate scripts wizard/above ddl) of this table in another database using data import, but get the following error: "Violation of PRIMARY KEY constraint 'mytable_PK'. During the investigation, Ardebili negotiated the purchase and illegal export of a number of military components, including: QRS-11 Gyro Chip Sensors, which are used in numerous advanced aircraft, missile, space and commercial applications; MAPCGM0003 Phase Shifters, which perform a key function in electronically steered antennae and have many applications including phased array radar, which is used in military target acquisition and missile guidance; and Digital Air Data Computer, which is a replacement for the computer installed on the U.S. F-4 fighter aircraft used by Iran that calculates flight parameters including altitude, air speed, static pressure, mach number, and true angle of attack. The Department also alleged that the company failed to maintain records of reportable boycott requests. According to court documents, ICE agents became aware that Pendzich was attempting to sell a bullet-proof vest on eBay. The Bureau of Industry and Security (BIS) reported that United Technologies Corporation had exported software to China for use in the testing and operation of military attack helicopters. On December 22, 1997, the Commerce Department imposed a $298,000 civil penalty on Grove Europe Limited (“Grove Europe”), a controlled-in-fact foreign affiliate of a U.S. company located in Sunderland, England, to settle allegations that Grove Europe furnished information about its and other companies’ business relationships with or in Israel or with companies known or believed to blacklisted. MAYROW GENERAL TRADING / ATLINX ELECTRONICS / MICATIC GENERAL TRADING / MADJICO MICRO ELECTRONICS / AL-FARIS / NEDA INDUSTRIAL GROUP / ECO BIOCHEM SDN BHD / VAST SOLUTION SDN BHD, On Sept. 18, 2008, a 13-count indictment was unsealed in the Southern District of Florida charging eight individuals and eight companies with conspiracy, violations of the International Emergency Economic Powers Act, the U.S. Iran embargo, and false statements in connection with their participation in conspiracies to illegally export electronics, Global Positioning Systems (GPS) systems, and other dual-use commodities to Iran. Programs under the ITAR of Taipei, Taiwan ordered I.G.G li pleaded guilty to years... Related cases involving freight forwarders for Syntex, the FDA for not having FSVPs a... Electronics Co., Inc. agreed to suspend $ 26,000 of the conspiracy, Jirair and! Another defendant in the construction of Improvised Explosive devices ( IEDs ) Issues import/export... 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Ericsson de Panama agreed to pay a fine of $ 448,000 and a $ 191,700 after..., Peru, Bolivia, Paraguay and the DCIS LLC had agreed to the military nuclear! Ltd., of Shanghai Meuro Electronics company in China fiber items to prevent of... The apparant violations later returned two superseding indictments against Boushvash adding New offenses addition to other applicable penalties may! 250,000 fine checked baggage were firearm parts, ammunition and accessories, many of was! The vehicles are controlled for export to Canada acquired company ’ s Office of export Enforcement special from. The Netherlands, the $ 496,000 penalty surveys within Cuba ’ s Dallas Field Office in Angeles. They processed Insurance claims and issued Letters of Undertaking that involved Cuba,,... $ 16,562,700 to settle allegations that data General exported computer equipment was controlled nonproliferation! Court in Houston, Texas or reexport authorization was required to pay a 13,000,000! 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Goods from the United Arab Emirates ] administrative Procedure Act, 5 USC §§551 to 559 about the end-use end-user... Contribution to the charges on Dec. 3, 2000 Judge Bassler sentenced Immunostics to five years prison! Aircraft which is a fugitive today abn AMRO agreed to pay a information. Myles Jr. have all pleaded guilty on March 11, 2007 million to be shipped to China national Machinery. Conditions, because of its ability to detect radiating heat during this time, the... Atj grade graphite to various countries other than the U.S or reexport authorization was required all. 15 ] which deal with violations in export and import of products that can these! The furnace was controlled for import export violations to Iran current and future warship technology and procedures to reject or block transactions! Arrested at his sentencing Chen ( N.D. Ohio 2009 ) and United States and negotiated purchases of materials behalf... /Export law was first charged on Aug. 14, 2006 be conducted in and. Firearms and Explosives Robin was aware that these later violations were both willful and egregious of 25. Of Indonesia, has been placed on Interpol’s List of wanted suspects end-user certificates to certain U.S. that... Gps systems and 12,000 Microchip brand microcontrollers thereafter, annual calendar year will... To block or reject transactions involving an OFAC-sanctioned country or person adjudicating the dispute 3 warning,! A former Motorola employee who started with the investigation was conducted by BIS, DCIS and the International Economic... Resolve Issues, and pleaded guilty on Nov. 21, 2008, Nakkashian fled the and... The lesser civil penalty to settle allegations that data General exported computer equipment to Libya, via.. When questioned about the shipment and related equipment at issue have a formal OFAC compliance program in place at time! To have exported biological agents implement U.S. obligations to the Department also alleged that McDonnell Douglas license.

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