Export Enforcement: Policing the Avenues of Trade

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Export EnforcementInvestigations and Sanctions• Criminal Investigation– Every case• Sanctions– Criminal fines and imprisonment– Civil fines and penalties– Denial of export privileges
What actions might makea case Criminal?• “Person/company knowingly and willfully…”– Knowing that the transaction was controlled (license wasrequired) and proceeding with the export without requiredauthorization.• Deliberate Ignorance (Self Blinding)• Corporate Knowledge– Individuals versus Corporate
Page 1 and 2: Export Enforcement: Policingthe Ave
Page 3 and 4: Export Enforcement…task is to pre
Page 5 and 6: Export Enforcement Field Offices•
Page 7 and 8: Why do we need controls onDual-Use
Page 9 and 10: Improvised Explosive Devices• P2
Page 11 and 12: Mayrow Case IndictmentUNITED STATES
Page 13 and 14: Top Cape TechnologiesCape Town Sout
Page 15 and 16: The CommoditiesTriggered Spark Gap
Page 17 and 18: WMD Use - Spark GapsCan be used as
Page 19 and 20: The Diversion Scheme…X$$$$$$
Page 21: UNITED STATES DISTRICT COURTFOR THE
Page 25 and 26: Criminal PenaltiesExport Administra
Page 27 and 28: Administrative PenaltiesIEEPA ENHAN
Page 29 and 30: “This is a fine mess you’vegott
Page 31 and 32: 2. Ignoring Red FlagsAsk yourself:
Page 33 and 34: 4. Non-Compliance withLicense Condi
Page 35 and 36: VoluntarySelf-DisclosuresYou find a
Page 37 and 38: True or False?You shouldn’t conta
Page 39 and 40: A Shared ResponsibilityKeeping the

Export Enforcement: Policing the Avenues of Trade

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