In another reminder that even EAR99 exports need to be screened, Multiwire Laboratories, Ltd., of Ithaca, New York, has settled for a $80,000 penalty for unscreened EAR99 exports to a party on the Entity List.
From the Department of Commerce, Bureau of Industry and Security:
On two occasions… Multiwire engaged in conduct prohibited by the [Export Administration] Regulations when it exported Real-Time Back Reflection Laue Camera Detectors and Accessories… designated EAR99, and valued at $177,156, to the University of Electronic Science and Technology of China ("UESTC") in Chengdu, People's Republic of China, without the required BIS licenses. At all relevant times, UESTC was listed on the Entity List… and a BIS license was required to export any item subject to the Regulations to that entity… However, Multiwire did not seek or obtain a license for either export of the items to UESTC.
Although an experienced exporter, Multiwire did not have an export control compliance program in place at any relevant time to screen foreign customers against the BIS Entity List (or other BIS or U.S. Government export controls lists)…
Multiwire shall be assessed a civil penalty in the amount of $80,000.
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