Archive for the ‘Sanctions’ Category

Offshore Marine Labs Pays $97,695 for Exports to UAE that Ended Up in Iran

Monday, March 4th, 2013 by Danielle McClellan

By: John Black

Offshore Marine Laboratories (“OML”), of Gardena, CA, agreed to pay $97,695 for alleged violations of the Iranian Transactions Regulations and Executive Order 13382, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” Between July 11, 2007, and July 17, 2008, OML allegedly exported to a company in the United Arab Emirates eight shipments of spare parts and supplies intended for supply to an offshore oil drilling rig located in Iranian waters. Both the rig owner and operator were located in Iran, and five of the shipments occurred after OFAC blocked the rig owner’s property and blocked interests in property.

Even though OML did not voluntarily disclose its actions to OFAC, OFAC determined that the alleged violations constitute a non-egregious case. OML’s $97,695 penalty is substantially less than the base penalty amount for the alleged violations, which was $167,000.

OFAC said the settlement amount is based on its consideration of these facts:

  • OML harmed sanctions program objectives because the transactions aided the development of Iranian petroleum resources;
  • OML had no OFAC compliance program in place at the time of the alleged violations;
  • OML has no history of prior OFAC violations;
  • OML demonstrated substantial cooperation with OFAC throughout the investigation, including agreeing to waive the expiration of the statute of limitations; and
  • OML took remedial measures by implementing an OFAC compliance program.

The numerous cases involving illegal shipments to the UAE and then on to Iran indicate:

  1. The government is watching for such shipments;
  2. There is a risk that things you send to the UAE may end up in Iran; and
  3. You want to make extra sure you are not knowingly or otherwise involved in something like this.

Posted in Iran, Nonproliferation & Nuclear, OFAC, Sanctions, Violations & Fines, Violations & Fines | Comments Off

Bank of Tokyo-Mitsubishi UFJ, Ltd. Pays $8 Million for OFAC Violations

Thursday, January 17th, 2013 by Danielle McClellan

By: John Black

The Office of Foreign Assets Control (OFAC) of the US Treasury Department announced on December 12, 2012 that the Bank of Tokyo-Mitsubishi UFJ, Ltd. (“BTMU”), Tokyo, Japan, agreed to pay $8,571,634 to settle apparent violations of US embargoes and sanctions on Burma, Iran, Sudan, Cuba, and persons involved in the proliferation of weapons of mass destruction. The violations occurred between April 3, 2006, and March 16, 2007.

According to OFAC, BTMU’s Tokyo operations concealed the involvement of countries or persons subject to U.S. sanctions in transactions that BTMU processed through financial institutions in the United States. Pursuant to written operational instructions utilized in a Tokyo operations center, BTMU employees engaged in stripping activities, which means they systematically deleted or omitted from payment messages any information referencing U.S. sanctions targets that would cause the funds to be blocked or rejected, prior to sending the transactions through the United States. These activities are similar to the so-called stripping activities for which many of the largest European banks have agreed to pay over $2 billion combined penalties to the US Government in the past.

According to OFAC, using its stripping practices, BTMU processed at least 97 funds transfers, with an aggregate value of approximately $5,898,943, through BTMU’s New York branch or other banks in the United States, in apparent violation of OFAC regulations. In 2007, BTMU’s senior management learned of these practices, it took the textbook correct actions: It began an internal review of historical transaction data and made a voluntary self-disclosure to OFAC.

OFAC said that it decided on the settlement amount based on its General Factors under OFAC’s Economic Sanctions Enforcement Guidelines in its regulations at 31 CFR Part 501, app. A. OFAC said these are the key factors that determined the amount of the penalty:

  • BTMU’s conduct concealed the involvement of U.S. sanctions targets and displayed reckless disregard for U.S. sanctions;
  • The general manager of the Operations Center in Tokyo knew or had reason to know that procedures had been implemented instructing employees to manipulate payment instructions;
  • BTMU’s conduct conferred a substantial economic benefit to targets of OFAC sanctions;
  • BTMU is a large, commercially sophisticated financial institution;
  • BTMU has undertaken significant remediation to improve its OFAC compliance policies and procedures;
  • BTMU substantially cooperated with OFAC’s investigation, including providing detailed and organized information regarding the apparent violations, and entering into a tolling agreement with OFAC; and
  • BTMU has no history of prior OFAC violations.

OFAC determined that BTMU’s violations constitute an “egregious case” despite the BTMU internal investigation, voluntary disclosure, and clean record. Obviously, the fact that these violations were the result of intentional actions to evade the rules, as opposed to an oversight or misunderstanding of the rules, weighed heavily in OFAC’s decision to impose a significant penalty for this egregious case.

Posted in Cuba, Iran, OFAC, Sanctions, Terrorism, Treasury Dept, Violations & Fines | Comments Off

US Publishes Rules to Prohibit Foreign Subsidiaries of US Companies from Doing Business with Iran

Thursday, January 17th, 2013 by Danielle McClellan

By: John Black

As we described in past issues, on December 26, 2012, the United States published a Federal Register notice to revise the Iranian Transaction and Sanctions Regulations (ITSR) to prohibit foreign-based subsidiaries of US companies from being involved in most activities with Iran. The Office of Foreign Assets Control (OFAC) in the US Treasury Department revised the ITSR to implement elements of the Iran Threat Reduction and Syria Human Rights Act of 2012 and multiple executive orders.

One of the key changes is that a new section 560.215 was added to the ITSR to prohibit entities owned or controlled by a United States person and established or maintained outside the United States from “knowingly” engaging in activities in which US persons have long been prohibited from engaging. These entities outside the United States, let’s call them foreign subsidiaries, are “owned or controlled by a US person if the US person:

  • Holds a 50 percent or greater equity interest by vote or value in the entity;
  • Holds a majority of seats on the board of directors of the entity; or
  • Otherwise controls the actions, policies, or personnel decisions of the entity.

Now, foreign subsidiaries, like US persons, are prohibited from knowingly engaging in any transaction directly or indirectly with Government of Iran or any person subject to the jurisdiction of Iran (for example, any entity located in Iran). “Knowingly” means having actual knowledge or reason to know. If you combine “reason to know” with engaging “indirectly” in an activity, you have a broad prohibition that could create huge compliance challenges for large and complex organizations.

There are two key exemptions from this new prohibition on foreign subsidiaries. The first applies to certain activities related to the natural gas pipeline from the Shah Deniz natural gas field in Azerbaijan’s sector of the Caspian Sea to Turkey and Europe (and related pipeline projects). The second exemption applies to authorized intelligence activities of the US Government, which frees up the US CIA and its affiliates from having to file voluntary disclosures for actions in Iran.

The ITSR includes a “winding down” general license provision that gives foreign subsidiaries a short time period to end their activities involving Iran. ITSR 560.555 authorizes activities normally incident to winding down newly prohibited activities through March 8, 2013 as long as no US persons are involved in those activities.

On a related point, section 4 of an October 9, 2012 Executive Order says that the penalties for a foreign subsidiaries violations may be assessed against the owning/controlling US company but the penalties will not be applied if the US person divests or terminates its business with the entity by February 6, 2013.

When the US Government imposed its trade embargo on Iran back in the mid-1990′s it intentionally allowed foreign subsidiaries to do business with Iran as long as the US parent company was not involved. Not only are those days gone, but now US persons face the difficult, and in some cases nearly impossible, task of ending their foreign subsidiaries activities in Iran or ending their ownership/control of the foreign subsidiary. Good luck will be needed for this impossible task, even for those companies who began ending their Iran activities long before these new rules entered into force.

For the complete Federal Register notice go to http://www.treasury.gov/resource-center/sanctions/Programs/Documents/fr77_75845.pdf

Posted in 2013, Federal Register, Iran, OFAC, Sanctions, Treasury Dept, Treasury Dept | Comments Off

Illegal Computer Exports to Iran Get 4 Years Prison Time and $10 Million Penalty

Friday, November 2nd, 2012 by Danielle McClellan

By John Black

U.S. District Judge Virginia M. Hernandez Covington sentenced Mohammad Reza “Ray” Hajian of Tampa, Florida to 4 years in federal prison for conspiracy to violate the International Emergency Economic Powers Act and the Iranian Transaction Regulations. The court also ordered Hajian to serve a one-year term of supervised release, upon his release from prison, and to forfeit $10 million, which are traceable to proceeds of the offense.   Hajian shipped approximately $14.85 million worth of computer and related equipment.

Between 2003 and 2011, Hajian conspired with others (aka “co-conspirators”) to illegally export enterprise level computers and related equipment from the United States to Iran, in violation of the U.S. embargo.  Ray and friends apparently went to great lengths to get away with this crime, but ultimately did not prove to be best criminals.

According to the US Government, to hide what they were doing Hajian and his co-conspirators shipped the computers and related equipment and moved the payments  to move to and from the United States and Iran through the United Arab Emirates.   (The UAE is a well-known and highly monitored diversion point for illegal trade with Iran.  Note to Ray and friends—next time try using a less obvious diversion point, perhaps one that is not being closely monitored by the US Government.)  Hajian and his co-conspirators communicated with each other via e-mail (thus creating records of their misdeeds). They employed fake identities, fake end-users, and coded language (I imagine an email saying “Dear Frank Roosevelt, I am glad you are not Iran and are in Cairo.  I will be sending the wedding cakes for the orphans in Lagos, Nigeria.  We will be shipping the CAKES on Al Italia directly to your office which is not in Dubai.  Please initiate the financing and payments for $3.2 hundred (not million) dollars.”)   I wonder if they also used those fake glasses/nose/mustache combo things.

Posted in Iran, Sanctions, Violations & Fines, Violations & Fines | Comments Off

Sanctions Against Iran Target Foreign Entities Owned or Controlled by U.S. Companies and Hold U.S. Companies Responsible for Their Violations

Friday, November 2nd, 2012 by Danielle McClellan

By Suzanne Reifman, Vinson & Elkins, 202-639-6577, sreifman@velaw.com

Over the past two years, the United States has continued to escalate sanctions against Iran, targeting both U.S. and non-U.S. persons and particularly those persons dealing with or supporting Iran’s energy and financial sectors. On July 1, 2010, the U.S. passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA). CISADA amended the existing Iran Sanctions Act of 1996 (ISA) and was designed to expand restrictions on non-U.S. entities that provide goods, services, or other support meeting particular monetary thresholds to Iran’s petroleum industry. The goal of the ISA, as amended by CISADA, is essentially to force non-U.S. companies to choose between doing business with Iran and doing business with the U.S. Following the passage of CISADA, the U.S. has continued to target non-U.S. companies that provide support to Iran through a series of laws and executive orders that have broadened the scope of sanctionable conduct and isolated Iran’s financial sector.

On August 10, 2012, President Obama signed the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA). The law contains many new prohibitions that affect a broad range of industries. In particular, the TRA addresses what many have described as a “loophole” in prior sanctions. Prior to the enactment of the TRA, in many instances foreign subsidiaries of U.S. companies could continue to legally engage in business with Iran as long as the business did not involve the provision of U.S. origin equipment or technology or require facilitation from U.S. persons. The prior sanctions were decidedly less restrictive than U.S. sanctions targeted against Cuba, under which foreign entities owned or controlled by U.S. companies are considered “U.S. persons” and fully subject to all of the sanctions’ requirements. However, under the TRA, any entity “owned or controlled by a United States person and established or maintained outside the United States” is now subject to the range of prohibitions applicable to U.S. persons or persons located in the U.S. with respect to dealings involving Iran.

It should be noted that the definition of “own or control” in TRA is broad, and means “holding more than 50 percent equity interest by vote or value in the entity;” “holding a majority of seats on the board of directors of the entity;” or “otherwise control[ling] the actions, policies, or personnel decisions of the entity.” The TRA does not identify the circumstances in which an entity can be “otherwise control[led]” and no other guidance has been issued. As such, U.S. companies that are parties to foreign joint ventures or similar entities in which they do not hold a majority equity interest or control a majority of board seats will still need to assess their level of control in order to determine whether these foreign entities could be construed as controlled by a U.S. company and, thus, subject to the Iran sanctions that apply to U.S. persons.

The TRA provided that the President would have to implement this provision within 60 days after the law’s enactment. Accordingly, Section 4 of the October 9, 2012 EO formally satisfied this statutory requirement. The EO provides that the penalties for violations of the prohibitions may be assessed against the U.S. person that owns or controls the entity that engaged in the prohibited transaction. The EO also provides that penalties shall not apply if the U.S. person that owns or controls the entity divests or terminates its business with the entity not later than February 6, 2013. Therefore, given the short grace period allowed for divestment/termination, U.S. companies will need to promptly determine:

  • Does the U.S. company own or control foreign entities that are engaged in conduct involving Iran that would violate U.S. sanctions against Iran? Note that in cases where U.S. companies are involved in joint ventures or other arrangements, it may be difficult to immediately identify all circumstances in which they control an entity based on the broad description set forth in the TRA.
  • If the foreign entity is engaged in business involving Iran, can this business be discontinued prior to February 6, 2013? Note that there is no general license or other authorization that would enable a U.S. company to provide unauthorized facilitation during this process. For example, a U.S. company could not participate in negotiations involving a foreign subsidiary and its Iranian customer to try and mitigate any breach of contract claims that would result from the foreign subsidiary’s termination of a contract.
  • If the owned or controlled foreign entity is either unable or unwilling to discontinue its business with Iran, can the U.S. company divest or terminate its interest in the foreign entity prior to February 6, 2013? Note that unlike the more general ISA sanctions, there is no “safe harbor” provision or other exception that would be granted to a foreign entity owned or controlled by a U.S. company that continues to do business with Iran (even if the entity is in the process of winding down or reducing its business).
  • Does the U.S. company have any of its own licenses from OFAC to engage in transactions involving Iran? If so, the company needs to consider whether it will need to cover any of its foreign owned or controlled foreign entities under these licenses going forward.
  • Can the U.S. company put the appropriate policies and procedures in place at its owned or controlled foreign entities to ensure compliance on a going-forward basis?

Given these issues, compliance with the TRA, as implemented by the October 9 EO, will present a major challenge for many U.S. companies and their owned or controlled foreign entities.

http://www.velaw.com/resources/SanctionsAgainstIranTargetForeignEntitiesOwnedControlledUSCompanies.aspx

Posted in BIS, Commerce Dept, Commerce Dept, EAR, Export License, Finance & Banking, Iran, Licensing, Sanctions | Comments Off

OFAC Drops CISADA Bomb on Two Banks

Tuesday, September 4th, 2012 by admin

By  R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC, 202-624-3949, Clif.Burns@bryancave.com, Export Law Blog, www.exportlawblog.com. Reprinted by permission.

The Office of Foreign Assets Control (“OFAC”) today applied sanctions <http://www.treasury.gov/ofac/downloads/561list.pdf> under the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 <http://www.hcfa.house.gov/111/MAR10505.pdf> against the Bank of Kunlun in China and the Elaf Islamic Bank in Iraq. Under these sanctions, U.S. financial institutions are “prohibited from opening or maintaining a correspondent account or a payable-through account” for the two banks, effectively cutting them off from foreign exchange and the U.S. financial system. <http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=35b678cbeb6866a7140739e0f6ef9eb2&rgn=div5&view=text&node=31:3.1.1.1.20&idno=31#31:3.1.1.1.20.2.1.1> This is the first time these sanctions have been applied. OFAC does not supply details on the basis for these actions other than to state that they were imposed under 561.201 of its Iranian Financial Sanctions Regulations.

Back in April, the Wall Street Journal identified <http://online.wsj.com/article/SB10001424052702303299604577323601794862004.html> Kunlun as significant player in providing financial services to Iran. Kunlun, which is controlled by state owned China National Petroleum Corp., on its website identifies the petroleum and petrochemical industries as its main customer base. Sanctions under section 561.201 are aimed at financial institutions that assist the Government of Iran to acquire WMD or support terrorist organizations, unlike 561.203 which is directed at foreign persons that facilitate transactions with blocked Iranian financial institutions such as the Central Bank of Iran or Bank Tejerat. Therefore, it seems reasonable to surmise that OFAC is taking the broad position that banks that help Iran sell petroleum products are, at least indirectly, furthering Iran’s nuclear program.

Posted in Iran, OFAC, Sanctions | Comments Off

President Obama Signs Executive Order Imposing Additional Sanctions on Syria

Wednesday, October 5th, 2011 by Holly Thorne

On August 18, 2011, President Obama made a statement calling for Syrian President Bashar-Al Assad to “step aside” in light of recent events in Syria. The President also signed an Executive Order imposing the following additional sanctions on the country:

  • Requires the immediate blocking of all assets of the Government of Syria subject to U.S. jurisdiction.
  • Prohibits U.S. persons from exporting or reexporting services to Syria.
  • Prohibits U.S. imports of Syrian-origin petroleum or petroleum products
  • Prohibits U.S. persons from having any dealings in or related to Syrian-origin petroleum or petroleum products.
  • Prohibits U.S. persons, wherever located, from operating or investing in Syria.
  • Prohibits U.S. persons from approving, financing, facilitating or guaranteeing transactions by foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person or within the U.S.

Due to the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SAA), most exports and reexports of U.S. origin products to Syria have been prohibited since May 2004; however, the export of humanitarian products to Syria, such as medicines, agricultural products and medical devices, are still permitted with the proper licenses.

The following Syrian energy companies have been also added to the Specially Designated Nationals (SDN) List. All property of these companies subject to U.S. jurisdiction must be blocked and U.S. persons cannot engage in any transactions with these parties:

  • The General Petroleum Corporation
  • Syrian Petroleum Company
  • Syrian Company for Oil Transport
  • Syrian Gas Company
  • SYTROL: Syria’s

Additional information

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Posted in Countries, Sanctions, Syria | Comments Off

Violations

Monday, August 29th, 2011 by Holly Thorne

Toll Global Forwarding Will Be Paying It Back

The Bureau of Industry and Security (BIS) announced that Rosedale, New York-based Toll Global Forwarding (successor to Baltrans Logistics, Inc.) of will be paying a $200,000 penalty for  nine violations of the Export Administration Regulations. The Violations include:

  • Causing, Aiding or Abetting an Act Prohibited by the Regulations on eight different occasions between 2005-2007. On these occasions, Toll Global acted as a freight forwarder and arranged for the export of electronic components designated as EAR99 items from the US to Bharat Dynamics Limited in India.
  • Causing, Aiding or Abetting an Act Prohibited by the Regulations in November 2007 by acting as a freight forwarder and arranging for the export of platinum pellets (designated as EAR99 items) from the US to Solid State Physics Laboratory in India.

The interesting point in this case is that this forwarding company was penalized even though it apparently was not the exporter.  This case points out that BIS will not hesitate to impose penalties on parties involved in illegal transactions, even if they are the exporter who has the primary responsibility for compliance.

More information: http://efoia.bis.doc.gov/exportcontrolviolations/e2216.PDF

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Swiss Technology Inc. Pleads Guilty to Violating Arms Export Control Act, to Pay $1.1 Million Penalty

New Jersey-based defense contracting company Swiss Technology, Inc. will pay a $1.1 million penalty for violations of the Arms Export Control Act for exports of U.S. “defense articles” to the People’s Republic of China.

In August 2004, Swiss Tech entered into contracts with the U.S. Department of Defense (DoD) to manufacture defense articles and parts for use in military operations.     Between 2004 and June 2009, the Clifton, N.J.-based company exported their DoD drawings, specifications, and sample parts to the People’s Republic of China without obtaining a license from the U.S. State Department. Swiss Tech intended to contract with the Chinese company to cheaply outsource the manufacture of parts for M4 and M16 rifles, as well as M249 machine guns used in military operations. Their money-saving scheme didn’t come to fruition and instead resulted Swiss Tech receiving a $1.1 million penalty.

More information:
http://www.justice.gov/usao/nj/Press/files/Swiss%20Tech%20Plea%20PR.html; www.justice.gov/usao/nj

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Singapore Man Exports Carbon Fiber Illegally, To Pay $100,000 to Settle Charges

Jianwei Ding is facing BIS is facing the music for allegedly  conspiring to export carbon fiber items from the United States to China without the required licenses.

Ding is the manager of Jowa Globaltech Pte. Ltd. (also known as FirmSpace), and Far Eastron Co., both Singapore-based companies that acquire items for customers, including the China Academy of Space Technology. Despite several warnings from US suppliers, Ding acted in concert with these companies, and possible others, to export Toray carbon fibers that are controlled for nuclear proliferation and national security reasons.

More information: http://efoia.bis.doc.gov/exportcontrolviolations/e2216.pdf)

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Posted in BIS, Commerce Dept, Information Technology, Sanctions, Violations & Fines | Comments Off

Available Customer Service/Export Compliance Position

Tuesday, July 5th, 2011 by Danielle McClellan
Basic Purpose

Responsible for the administration of customer service issues, customer communications and customer requests and orders on a daily basis. Maintain and ensure integrity of all customer data in the business systems, including customer property, orders and associated dollars.  Assure that all customer requests for quotes are properly managed in the PTS system. Responsible for maintaining and ensuring accurate backlog, orders, and market segmentation data.

Position Specification
Education/Experience

  • An Associates or Bachelors degree with a minimum of 5 years related industry work experience.
  • Solid understanding of military and commercial export compliance regulations.
  • Demonstrated ability to effectively and professionally communicate with all levels in the organization, vendors and customers.
  • Understanding of pricing models.
  • Proven negotiation skills.
  • Strong verbal and written communication skills.
  • Strong computer skills with working knowledge of MS Office and Access.
  • Proven team-work capabilities and experience.
 Additional Requirements

  • Understanding of the Fourth Shift or Syteline ERP system.
  • Able to handle and resolve customer complaints and problems and escalate when required.
  • Willing and able to develop long-term relationships internally and externally.
  • Attention to detail.
Functional Scope

The Customer Service Representative provides support to both the internal and external customers of the company.  This position plays an active role in the maintenance and management of the various business systems. Success in this role will require a proactive approach and the ability to create and implement process improvements to ensure that the systems and processes are as robust as possible to provide superior service to the customers.
Duties and Responsibilities

  • Responsible for the accurate and timely management of all sales order activity.
  • Ensure all sales data is accurate and complete in order to maintain order, market and backlog reporting integrity including schedule and associated dollars.
  • Responsible for raising export compliance concerns to the DECA or DECA backup when required.
  • Serves as a central point of contact for customer inquiries. Provides customers with updated order and delivery status.
  • Responsible for inputting data (RFQs, pricing, status, etc) into the PTS (Proposal Tracking System) and ensuring that all data is accurate and complete and up to date.
  • Provides engineering with request for quote information required to initiate estimating process.
  • Performs contract review and order acceptance process. Controls and maintains master contracts/ purchase order files.
  • Assists with the configuration control process.
  • Performs the EDI transaction conversion to the business system. Tracks changes in delivery dates, prices and handles terminations.
  • Maintains customer information in the various business systems.
  • Responsible for disseminating Terms and Conditions, special shipping instructions, configuration changes and quality requirements throughout the organization.
  • Assists accounting with invoicing and collection issues.
  • Review Customer Scorecards.
  • Perform other duties as required by the business and as instructed by supervisor.
Essential Functions of Position

Interpersonal Skills

  • Must be able to communicate clearly and effectively with all levels of personnel within the organization and the customer.
  • Must be able to communicate orally and/or in writing as to work requirements, work in progress, and/or work completion
  • Must be able to follow complex instructions and/or directions. May require ability to decide on a course/sequence of action

Schedule and Planning

  • Must be able to schedule and organize time effectively to satisfactorily complete assigned tasks and functions.

Physical Effort

  • Minimal physical effort
  • May be required to travel occasionally to customer premises or corporate office.
  • Operate personal computer.

Working Conditions

  • Primarily work in office areas with exposure to shop floor.
  • Generally responsible for the safety and clean up of own work area.

Disclaimer

  • The above information on this job description has been designed to indicate the general nature and level of work performed by employees within this classification. It is not designed to contain or be interpreted as a comprehensive inventory of all duties, responsibility and qualification required of employees assigned to this job.

Contact Pamela R. Daly regarding this position at:

Barnes Aerospace

169 Kennedy Rd

Windsor, CT 06095

P: 860-687-5270

F: 401-228-0823

pdaly@barnesaero.com

Posted in BIS, Commerce Dept, DDTC, Defense Trade Controls, EAR, Export License, Jobs/Careers, Jobs/Careers, OFAC, Sanctions, State Dept, State Dept, USA Regulations | Comments Off

Balli Group and Ballie Aviation Discloses More Violations, $2 Million Penalty Unsuspended

Monday, June 27th, 2011 by Anna Barone

By: Anna Barone

As the result of a self-disclosure, Balli Group and Balli Aviation’s the Bureau of Industry and Security has unsuspended the previously suspended $2 million penalty. The suspended $2 million was a portion of the $15 Million penalty levied against Balli Group and Balli Aviation on February 5th.  They will not be debarred or suspended from export transactions if the penalty is paid on schedule.

More Information available: http://efoia.bis.doc.gov/ExportControlViolations/TOCExportViolations.htm

Posted in Sanctions, Violations & Fines | Comments Off

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