International Trade Enforcement Roundup | November 2…

What happened? Ray Hunt, an Iranian-born U.S. citizen living in Alabama, was charged after exporting U.S.- controlled items used in the oil and gas industry to Iran. Hunt used his company, Vega Tools LLC, to buy valves, tubing, and other items from American producers and resell them to Iranian companies using the UAE and Turkey as transshipment points. Hunt also falsified his export records to deceive shipping companies about the ultimate destination and value of the goods.

Read the indictment here. Read the press release here.

Notably. The indictment shows that the UAE remains a preferred transshipment point for U.S.-origin products destined for Iran (and Syria). The UAE is also a common transshipment point for controlled exports bound for Russia or Belarus, according to an August BIS FAQ.

BIS Issues Charging Letter Against Mohammad Alhamra and WEBS Electronics Trading Compa- ny for Violating U.S. Export Controls (DOC/BIS Action)

Those involved. Mohammad Alhamra; WEBS Electronic Trading Company, a UAE-based trading company.

Charges with penalties. Solicitation and Attempt; Engaging in Prohibited Conduct by Re-exporting Controlled Items to Syria without BIS Authorization; Engaging in Prohibited Conduct by Re-exporting Controlled Items to Iran without BIS Authorization; Misrepresenting and Concealing Facts to an Official of a United States Agency (up to $330,947 in penalties per violation or twice the value of the transaction and denial of export privileges). What happened? In April 2018, a BIS Export Control Officer (ECO) became aware that WEBS was attempting to re-export a U.S.-origin switch and transceiver from the UAE to Syria. During a post-shipment verification (PSV), Alhamra denied selling to Syria. A month later, the ECO became aware of another attempt to re-export U.S.-origin technology to Syria and conducted another PSV. This time, Alhamra admitted that up to 80% of WEBS sales were to Syria. Upon further investigation, BIS found that Alhamra had re-exported U.S.-origin items numerous times to a company in Syria and a customer in Iran.

Read the charging letter here. Read the press release here.

Notably. Non-U.S. companies must comply with the same U.S. export control laws that U.S. companies comply with when exporting U.S.-origin products. Re-exporting U.S.-origin products, even EAR99 products, to either Syria or Iran requires a BIS license in nearly every case.

Iranian Airlines – Temporary Denial Orders (DOC/BIS Action)

On November 8, BIS renewed a previously issued TDO against Mahan Airways (Mahan), Pejman Mahmood Kosarayanifard, Mahmoud Amini, Kerman Aviation, Sirjanco Trading LLC, Mahan Air General Trading LLC, Mehdi Bahrami, Al Naser Airlines, Ali Abdullah Alhay, Bahar Safwa General Trading, Sky Blue Bird Group, and Issam Shammout. BIS cited Mahan’s continued operation in violation of the May 13, 2022 TDO and the EAR: Mahan re-exported an aircraft, obtained through Al Naser Airlines, to Russia without a license and continues to operate three unauthorized aircraft between Russia, Iran, and the UAE.

The Federal Register notice can be found here.

4 International Trade Enforcement Roundup |

Powered by