Export Controls (U.S.)

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Lack of Familiarity with US Sanctions Results in Steel Manufacturer Settling with OFAC for Apparent Violations

Client Updates

On April 19, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the entry into a $435,003 settlement with Alliance Steel, Inc. (“Alliance”), a fully integrated manufacturer of metal building systems, structural steel, and components headquartered in Oklahoma City, Oklahoma, for 61 apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”), mainly resulting from the Company’s lack of understanding as to the application of U.S. sanctions laws to its isolated international activity.

U.S. Customs Expands Enforcement Against Forced Labor Imports with Seizure of Malaysian PPE

Client Updates

On March 29, U.S. Customs and Border Protection (“CBP”) announced that it will begin seizing imports of certain disposable gloves manufactured by Top Glove Corp. Bhd. (“Top Glove”), the world’s leading producer of disposable rubber gloves based in Malaysia, upon determining that sufficient evidence exists to support a finding that Top Glove is manufacturing the products with the use of convict, forced, or indentured labor.1

Incorrect Export Licensing Determinations Result in Wireless Telecommunications Equipment Manufacturer Settling with BIS for Apparent Export Control Violations

Client Updates

On March 19, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the entry into a $122,000 settlement with Comtech XiCom Technology, Inc. (“Comtech XiCom”), a leading supplier of high power amplifiers for satellite communications based in Santa Clara, CA, for three apparent violations of the Export Administration Regulations (“EAR”), caused by Comtech XiCom’s mistaken belief that certain exports could be made without BIS license or authorization.