Tina Chen, a resident of Las Vegas and owner of electronics and computer components exporter Top One Zone, was indicted by a federal grand jury for conspiracy to export goods from the U.S. to Iran, the Department of Justice said in a May 28 news release. Chen allegedly worked with others to purchase and ship goods from U.S. companies through entities in Hong Kong to individuals in Iran without a license from the Treasury Department's Office of Foreign Assets Control. Chen hid the identities of the end-users, DOJ alleged. She is charged with one count of conspiracy to unlawfully export goods to Iran in violation of the International Emergency Economic Powers Act and the Iranian Transactions and Sanctions Regulations -- a charge that carries a maximum penalty of 20 years in prison and a $1 million fine.
Iran Export Controls
Certain items on the Commerce Control List require a license from BIS to export them to Iran. The Iranian Transactions Sanctions Regulations (ITSR) (31 CFR Part 560) also prohibit the export and reexport of goods to Iran subject to EAR.
A “groundbreaking” settlement agreement between a German software company and three U.S. agencies (see 2104290069 and 2105070042) may signal greater enforcement of sanctions and export violations and present more compliance challenges for industry, law firms said. The more than $8 million settlement between SAP SE and the Justice, Treasury and Commerce departments -- the first non-prosecution agreement under the Justice Department's revised voluntary disclosure policies (see 2008180043) -- also includes several important lessons for businesses and may lay out how monitorships can be avoided, the firms said.
Export Compliance Daily is providing readers with the top stories for May 10-14 in case you missed them. You can find any article by searching on the title or by clicking on the hyperlinked reference number.
Following the Department of Justice's first resolution of action under a new export control tool, greater efforts should be made to conduct export-related due diligence and act on those recommendations, according to a May 6 analysis from Sidley Austin. Merely conducting audits of exports and sanctions is not good enough anymore, Sidley said. Implementing audit recommendations and putting in place a robust process to receive, investigate and elevate whistleblower complaints should be a priority following the DOJ's settlement with German software company SAP SE.
Export Compliance Daily is providing readers with the top stories for April 26-30 in case you missed them. You can find any article by searching on the title or by clicking on the hyperlinked reference number.
A German software company agreed to pay more than $8 million in fines after it admitted to violating U.S. export controls and sanctions against Iran, the Justice, Treasury and Commerce departments announced April 29. The company, SAP SE, came to settlement agreements with all three agencies after it voluntarily disclosed the violations, which included illegal exports and reexports of U.S.-origin software.
Export Compliance Daily is providing readers with the top stories for April 19-23 in case you missed them. You can find any article by searching on the title or by clicking on the hyperlinked reference number.
The Office of Foreign Assets Control fined an Oklahoma steel manufacturer about $435,000 for violating U.S. sanctions against Iran, OFAC said April 19. Alliance Steel committed 61 sanctions violation by maintaining a “business relationship” with an Iranian company for five years, OFAC said.
The Office of Foreign Assets Control fined an Italian gas equipment manufacturer $950,000 for violating U.S. sanctions against Iran, OFAC said in a March 26 notice. The company, Nordgas S.r.l., knowingly reexported 27 shipments of U.S.-origin “air pressure switches” to Iran, OFAC said, and caused a U.S. company to “indirectly” export goods to Iran.
The Office of Foreign Assets Control fined a Cleveland process controls and instrument manufacturer more than $215,000 for violating U.S. sanctions against Iran, OFAC said in a March 15 notice. The company, UniControl, Inc., exported goods to European companies despite knowing they would ultimately be sent to Iran, OFAC said. The agency said the company failed to “act on multiple apparent warning signs.”