The Bureau of Industry and Security will likely issue more penalty announcements this year for export control violations, a former senior BIS enforcement official said, suggesting the current state of enforcement is unprecedented.
Behrouz Mokhtari of McLean, Virginia, and Tehran pleaded guilty Jan. 9 to two conspiracies to violate U.S. sanctions on Iran "by engaging in business activities on behalf of Iranian entities" without getting a license from the Treasury Department's Office of Foreign Assets Control, DOJ announced Jan. 9. Mokhtari will forfeit money, property and assets obtained from the schemes, including a Campbell, California, home, and a money judgment of over $2.8 million, DOJ said. The defendant faces a maximum of five years in prison for each of the two conspiracy counts.
Electronics distribution company Broad Tech System and its president and owner, Tao Jiang of Riverside, California, pleaded guilty Jan. 11 to participating in a conspiracy to illegally ship chemicals made or distributed by a Rhode Island-based company to a Chinese firm with ties to the Chinese military, the U.S. Attorney's Office for the District of Rhode Island announced. Jiang and Broad Tech admitted to violating the Export Control Act and conspiring to commit money laundering.
Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in keeping pace with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2023.
The Bureau of Industry and Security this week unveiled a new set of changes to its voluntary self-disclosure policies that it hopes will allow compliance professionals to spend more time and money preventing serious export violations and less resources on reporting minor ones. The agency also said it has seen a sharp uptick in self-disclosures of serious violations over the last year and has been getting more tips from businesses about possible violations committed by their competitors.
The Commerce Department’s export enforcement actions in 2023 resulted in the “highest number ever” of convictions, temporary denial orders and post-conviction denial orders, the Bureau of Industry and Security wrote in a year-end review. It also said it worked with foreign governments to complete over 1,500 end-use checks, “our most ever in a single year,” and added more than 465 parties from China, Iran, Russia and elsewhere to the Entity List.