Apparel 
Requirements
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BXA
Announces Various Penalties for Violation |
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May
14 , 2002 Violation of Encryption regulations The BXA imposed a $95,000 civil penalty on Neopoint, Inc. of San Diego, CA to settle allegations that the company exported encryption software to South Korea in violation of U.S. export control laws. The BXA charged that the company exported 128-bit encryption software (5D002) without obtaining a license pursuant to 15 C.F.R. section 742.4(a) and by transferring the software with knowledge that a license was required in violation of section 764.2(e). Antiboycott violations Two affiliated crude oil trading companies - Koch Petroleum Group, L.P. and Koch Refining International Pte. Ltd., agreed to pay a total of $37,000 to settle allegations that the companies committed 37 violations of the antiboycott provisions where the company failed to report the antiboycott requests within the prescribed time period. False Statement Violations A $10,000 civil penalty has been imposed to settle a case against Mr. Don Yamaguchi of Houston, TX, doing business as Kaiyo USA. Yamaguchi advised a U.S. exporter that modems were to be exported from the United States to Japan when, in fact, Japan was not the country of ultimate destination. Based on this information, the U.S. exporter made a false statement on its Shipper's Export Declaration (SED) for the transaction when it represented that the modems ultimately were destined for Japan. EAR Export License Violations BXA imposed a $186,000 civil penalty against Waters Instruments, Inc. of Minneapolis, MN, to resolve allegations that the company violated the EAR by numerous exportations of electric cattle prods (ECCN item 0A84) to various countries without obtaining the required export licenses. Our law firm assists companies where guidance is needed in regard to the export, antiboycott, or foreign corrupt practices laws and regulations. We help companies (1) implement compliance programs, (2) assessing existing programs, and (3) address liability issues surrounding violations of the laws. If you have any questions about the issues raised in this newsletter, please contact George R. Tuttle, Sr. at (415) 986-8780 or via email at grt@tuttlelaw.com.
Copyright © 2002 by Tuttle Law Offices. All rights reserved. Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.
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