International Trade Enforcement Roundup | October 2022

U.K. Businessman Graham Bonham-Carter Indicted for Sanctions Evasion benefiting Russian Oligarch Oleg Vladimirovich Deripaska (DOJ)

Those involved. Graham Bonham-Carter

Charges and penalties. Conspiracy to evade U.S. sanctions (maximum of 20 years); Violation of the International Emergency Economic Powers Act (IEEPA) (maximum of 20 years); and Wire Fraud (maximum of 20 years).

What happened? On October 11, Graham Bonham-Carter was indicted for violating U.S. sanctions. Bonham- Carter apparently began working for Russian oligarch Oleg Vladimirovich Deripaska in July 2003. In April 2018, OFAC designated Deripaska as a Specially Designated National (SDN). However, Bonham-Carter continued to work for Deripaska, engaging in over $1 million of illicit transactions to fund real estate properties in the United States for Deripaska’s benefit. Bonham-Carter also attempted to transfer art from the United States to the UK through misrepresentations, concealing Deripaska’s ownership of the art. Bonham-Carter was arrested, and the U.S. government is seeking his extradition.

Read the press release here.

Notably. The indictment further exemplifies the reach of U.S. sanctions laws. Special consideration should be given to any work done on behalf of or in furtherance of, those on the SDN list.

Intertech Trading Corp. Sentenced to Pay $140,000 for Failure to File Export Information on Shipments of Lab Equipment to Russia and Ukraine (DOJ)

Those involved. Intertech Trading Corporation (Intertech), a New Hampshire laboratory equipment distributor.

Charges with penalties. 14 felony counts of failure to file export information ($140,000 in fines and the imposition of a two-year corporate monitor).

What happened? On October 17, Intertech was sentenced to the maximum allowable fine for falsely describing the nature and value of the exported items on commercial invoices and shipping forms pertaining to exports to Russia, Ukraine, and elsewhere. The undervaluation allowed Intertech to avoid filing Electronic Export Information with the DOC and the Department of Homeland Security.

Read the press release detailing the sentencing here.

Notably. Mischaracterizing and undervaluing exports impair the effective administration of export control laws. Recently, the federal government has made it a priority to detect and enforce mislabeling. Companies with knowledge of potential deceptive behavior should consider self-disclosing violations to the DOC and DOJ.

Florida Man Guilty of Violating International Economic Powers Act (DOJ)

Those involved. Eddy Johans Coopmans

Charges with penalties. Conspiracy to smuggle goods out of the United States and to violate the International Emergency Economic Powers Act (IEEPA) (5 years in prison).

What happened? On October 5, Eddy Johans Coopmans, of Ponte Verde, Florida, pleaded guilty to conspiracy to smuggle goods out of the United States and violating the IEEPA. Coopmans, with a co-conspirator, agreed to export Space Grade Field Programmable Gate Array Circuits to Russia and Short Wave Infrared Cameras to China. Coopmans and the other individual conspired with perceived accomplices, paid them over $1 million for

3 International Trade Enforcement Roundup |

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