ExportLawBlog » Entity Record Screening Complications Can Be Pricey: The Abbreviated Model


VNIEFF via http://www.vniief.ru/en/resources/2d252b804af3374599869d5b6de8bab2/12.jpg [Fair Use]BIS just lately introduced a settlement with Mohawk World Logistics Company for $155,000 ($20,000 of which was suspended if Mohawk behaved itself throughout a probationary interval).   The penalty arose out of Mohawk’s export of things to establishments on the Entity Record with out the required license.  In each cases, Mohawk screened in opposition to the checklist, however issues went fallacious.

One of many exports went to the College of Digital Science and Expertise of China (“UESTC”).  Quite than display screen in opposition to the complete title of the college, Mohawk simply screened the college’s commonly-used acronym — UESTC.   In consequence, it did not flag the transaction.  BIS, within the charging paperwork, famous that the handle it had for UESTC was a “near-match” (no matter which means) to the handle proven for UESTC on the Entity Record.  The take-away right here, after all, is that exporters ought to display screen total names and addresses.

One in all the different exports was to the All-Russian Scientific Analysis Institute of Experimental Physics in any other case often known as VNIIEF (as a result of the title in Russian – Всероссийский Научно-Исследовательский Институт Експериментальной Физики [Vserossiyskiy Nauchno-Issledovatelckiy Eksperimentalnoy Fiziki] — is abbreviated as ВНИИЕФ or VNIIEF when transliterated to the Roman alphabet — bought that?).  Now for this export the transliterated Roman abbreviation resulted in successful, which, for some unexplained motive, the Mohawk export supervisor merely ignored.

A footnote dropped by BIS on VNIIEF reveals the perils of overseas language names and the Entity Record.   The preliminary itemizing was for the “All-Union” Scientific Analysis Institute of Experimental Physics.  When this was up to date to the proper “All-Russian” Scientific Analysis Institute of Experimental Physics in 2011, the widespread acronym VNIIEF (however not ARSIEP, which is, clearly, a greater acronym) was added.  However searches of VNIIEF, the widespread title of that entity, previous to 2011 wouldn’t have turned up something.   The ethical of this story:  don’t search abbreviations or acronyms.

The advantageous right here appears excessive.   The products concerned have been EAR99 objects and value, in complete, about $200,000.  A license in all probability would have been granted if requested so there’s no palpable hurt to nationwide safety right here.  And Mohawk tried to display screen however simply didn’t do an excellent job of it.  Nevertheless, it’s not like they, like many exporters, didn’t even attempt to display screen the recipients.   Granted the inexplicable exercise of the Mohawk supervisor in overriding the hit for VNIIEF would allow some aggravation of the penalty.  And maybe the failure to display screen addresses once they had a “close to match” of the proper handle additional irritated BIS.  Nevertheless it appears to me right here that BIS is fining incompetence somewhat than malice.

 

 

 

https://efoia.bis.doc.gov/index.php/paperwork/export-violations/export-violations-2018/1193-e2561/file

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