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BIS Combating IED Networks; Says 29 Persons Sentenced to 572 Months in FY 2011 for Export Violations

The Bureau of Industry and Security is putting a high priority on disrupting networks that procure parts and components for use in improvised explosive devices (IEDs), said BIS Assistant Secretary for Export Enforcement David Mills in the opening remarks for the second day of the Update 2012 Conference on Export Controls and Policy. IED procurement networks mostly trade in electronic components with widespread consumer applications, Mills said. These components can be exported to most countries without a license, but are then being reexported to destinations requiring a license for use in making IEDs, he said. Mills also emphasized BIS’ patience and persistence in export investigations, which can often lead to discovery of other related violations by other companies in a network, and encouraged companies to submit voluntary self disclosures if they have committed violations.

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BIS is stressing individual responsibility in its enforcement actions, Mills said. In fiscal year 2011, 29 individuals were sentenced to a total of 572 months in prison as a result of BIS investigations, as compared to only 10 companies that received penalties, he said. 26 denial orders were issued as a result of these 39 cases in FY 2011 cases. BIS has imposed penalties in 27 cases so far in FY 2012, and issued 24 denial orders in these cases.

However, most investigations do not result in penalties, Mills said. BIS sent 227 warning letters to exporters in FY 2011, and has sent 181 warning letters so far in FY 2012. Fully 97% of cases involving voluntary self disclosures did not result in penalties in FY 2011, he said.