International Trade Enforcement Roundup | October 2022

help smuggling items out of the United States, and made false statements to government regulators. Coopmans now faces up to 5 years in federal prison.

Read the press release detailing the plea agreement here.

Notably. Whether or not an export occurs, individuals who violate U.S. export control laws can be held responsible and punished with substantial jail time.

Russia Airlines - Temporary Denial Orders (TDO)

On October 13, BIS issued a TDO against URAL Airlines JSC (URAL) citing apparent ongoing violations of the comprehensive export controls imposed on Russia. URAL joins eight other Russian airlines under TDOs, each of which ban the companies from participating in transactions subject to the Export Administration Regulations (EAR), including exports from the United States and re-exports abroad. BIS also renewed previously issued TDOs against Aviastar-TU (April 21, 2022), UTair Aviation JSC (April 7, 2022), and PJSC Aeroflot (April 7, 2022). These renewed TDOs will remain in effect for an additional 180 days.


Seagate Technology Holdings Warned It May Be Charged (DOC)

Those involved. Seagate Technology Holdings, an American data storage company.

Charges and penalties. Charges TBD (up to $300,000 in penalties per violation or twice the value of the transaction for violating EAR).

What happened? On October 26, Seagate Technology Holdings disclosed it had been warned by the U.S. government that it may have violated export control laws when it provided hard disk drives to Huawei Technologies. The warning was made in a proposed charging letter issued by the DOC. Seagate apparently has taken the position that its hard disk drives are not subject to the EAR because the drives are not a direct product of U.S. technology or software, nor made from a plant that is itself a direct product of U.S. technology or software. The disk drives are made in China and Thailand.

Read the Reuters exclusive story here.

Notably. Huawei is on the DOC’s Entity List, and a license is required for exports and re-exports to Huawei, even for those items manufactured outside of the United States if they fall under the direct product rule or the de minimis rule. This is a test case of how far the DOC will go in interpreting the foreign direct product rule to capture foreign-made items. Stay tuned for developments on the case.


OFAC Settles with Bittrex, Inc. for over $24 million Related to Apparent Violations of Multiple Sanctions Programs (Department of Treasury)

Those involved. Bittrex, Inc. (Bittrex) a virtual currency exchange based in Bellevue, Washington.

Charges and penalties. 116,421 violations of multiple sanctions programs. Bittrex agreed to pay over $24 million in penalties. The maximum applicable civil penalty was close to $35 billion.

4 International Trade Enforcement Roundup |

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