A sales manager with PPG Industries was charged with violation of two export control laws relating to one export transaction. The Bureau ofIndustry & Security charged the manager with a violation of15 CFR 764.2(d) Conspiracy and 15 CFR 764.2(b) Causing, Aiding or Abetting a Violation of the Regulations. The violations were related to the export of epoxy paint and paint thinner to a nuclear power plant under construction in Pakistan, without the required export license from the Department of Commerce. In furtherance of the conspiracy, the manager directed another sales representative to make the order appear to be a domestic transaction to avoid internal export compliance review and arranged for the freight forwarder to transship the goods through Hong Kong. The sales manager knew that the goods required a license and that export without a license through Hong Kong would be considered an intentional violation, which would result in fines and jail time. The manager was ordered to pay the maximum civil penalty of $250,000 per violation, but was not ordered to serve any time in jail; however, the civil fine was reduced to $15,000, payable by an initial payment of $5,000 followed by four installments of $2,500 each.
Moral of the Story:
Think of the consequences before you act. You could be personally liable for payment of an export penalty.
No comments:
Post a Comment