The EAR and ITAR subject violators to separate fines for violations, which – depending on criminal or civil liability – can run up to $1M or $250K per violation, respectively.  How does this work?

 

Suppose that (without a license) you accidentally send design documents for controlled technology to a foreign client.  It was a mistake, but you sent three different design documents for three different controlled technologies.  Given that the disclosure was a mistake, the violation will likely only subject you to civil penalties.  There were three violations, so in total, you could potentially be subject to $750K in fines for one mistaken disclosure.

 

Though compliance is complex – and often expensive – there are substantial penalties associated with non-compliance.  You must make proper efforts to invest in compliance to ensure that you and your firm do not violate relevant deemed export regulations.

Posted on November 29th, 2016 by admin
Filed under: EAR, ITAR