Normally, we hear about BIS issuing penalties to export companies, but there may be a new trend in the works. Many of you are familiar with the conviction of the university professor for violation of Arms Export Control Act. This individual was sentenced to 4 years in jail and more in fines.
Most recently, the Commerce Department's Bureau of Industry and Security (BIS) issued a civil penalty to a U.S. manufacturer and an employee for unlicensed exports of certain semiconductor components. The manager for the manufacturer was issued a $15,000 civil penalty for making false and misleading statements to BIS Special Agents during the investigation of the company. This is one of the few cases in which a corporate export compliance manager has been assessed civil penalties. Exporters and their export compliance departments should take heed and invest some time in reviewing their compliance programs and educating employees at all levels of the consequences of violating export control regulations.
Here’s a question for our readers. Do you think the manager will end up paying the $15,000 penalty out of her pocket?
