Belgian Company Attempting to Procure Accelerometers for Chinese Military End Users Receives TDO from BIS

On August 26, 2022, the Department of Commerce, Bureau of Industry and Security (BIS) issued a Temporary Denial Order (TDO) to Hans De Geetere and Knokke-Heist Support Corporation Management a/k/a/ Hasa-Invest of Belgium.

The order was based on the parties "acquiring or attempting to acquire under false pretenses accelerometers, items subject to the Regulations, from the United States on behalf of prohibited end-users or for prohibited end-uses in China." Specifically, the conduct involved U.S.-origin accelerometers used by the aerospace and defense industries following a post-shipment verification by BIS.

The TDO prohibits the parties from participating in activities subject to the Export Administration Regulations (EAR) including exports, reexports, and retransfers as detailed in the TDO. The TDO is valid for 180 days and may be renewed.

This case serves as a reminder of the importance of continuous screening for parties from all countries as sanctions lists are subject to frequent change.  A copy of the TDO is available on the BIS website and was released as a Federal Register Notice (87 FR 53716). The parties were also added to the BIS Denied Persons List (DPL).