12.07.2015 Views

Export Enforcement: Policing the Avenues of Trade

Export Enforcement: Policing the Avenues of Trade

Export Enforcement: Policing the Avenues of Trade

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Administrative SanctionsAdministrative Penalties in <strong>Export</strong> AdministrationRegulations:• Strict Liability -- knowledge is not a prerequisite forimposition <strong>of</strong> an administrative penalty• Administrative violations must be proven by apreponderance <strong>of</strong> <strong>the</strong> evidence…51%• 5 year statute <strong>of</strong> limitations on administrativeenforcement cases

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