Failing to Keep Current with Classifications Leads to Civil Penalty for NJ-based Company

2017/10/16

By: Ashleigh Foor

During the second week of September, Bright Lights USA, a Barrington, NJ-based company, received a $400,000 civil penalty from the State Department’s Directorate of Defense Trade Controls (DDTC) for exporting unauthorized defense components and technical data, which violates the International Traffic in Arms Regulations (ITAR).

Bright Lights notified DDTC of two ITAR violations in voluntary self-disclosures filed with the agency in April 2013 and June 2016.

Bright Lights failed to stay current with the former Obama administration’s Export Control Reform (ECR) regarding  the transition of ITAR-related commodities/technology from the State Department’s US Munitions List to the Commerce Control List. The wrong commodity jurisdiction was selected and resulted in export violations for both the physical export of the items and the illegal transfer of technology made by the company.

Want to make sure your company is staying compliant? We have an upcoming webinar on classifications:

EAR Hardware and Materials Classifications: Learning By Doing

Practice Makes Perfect—A Two-Part Webinar that Combines Hands-On Exercises, Discussions, and Instruction. October 25, 2017 & November 8, 2017

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