US: IN EXPORT CONTROL CASE AUTHORITIES IMPOSE CIVIL FINE AND COMPELS THE HIRING OF A COMPLIANCE OFFICIAL OR CEASE OPERATIONS

On 25 October, an article from Bass, Berry & Sims said that the Commerce Department’s Bureau of Industry and Security (BIS) had announced that it imposed a civil penalty fine against VTA Telecom Corporation for the unauthorised export of controlled commodities to Vietnam.  Additionally, BIS is requiring VTA to improve its export control compliance efforts and retain a Director of Trade Compliance.  Alternatively, VTA can dissolve or cease operations.  VTA was found to have exported without the necessary licence computer processing chips, provided false statements to its US supplier and US Customs, and did so knowingly.  The article says that what is notable about this matter is BIS’s requirement that VTA spend a specified amount of money developing an internal compliance programme (ICP) and designating a company official to oversee compliance with the EAR –  or go out of business.

https://www.bassberrygovcontrade.com/bis-civil-fine-compliance-official

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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