U.S. BIS issues “charging letter” against electronics trading company and its owner for violating U.S. export controls

Exports of U.S. telecommunications equipment and related commodities to Syria and Iran.

Electronics trading company and its owner

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce issued an administrative charging letter* against an electronics trading company and its owner, alleging violations of the Export Administration Regulations (EAR) related to exports of U.S. telecommunications equipment and related commodities to Syria and Iran.

According to the BIS release [PDF 120 KB] (November 4, 2022), the alleged violations were also related to misrepresentations and concealment of facts to BIS officials regarding the exports.


As alleged in the charging letter:

  • The Office of Export Enforcement (OEE) launched an investigation after a BIS export control officer learned that the electronics trading company and its owner were attempting to reexport U.S.-origin items from the United Arab Emirates (UAE) to Syria and conducted end-use checks.
  • The investigation determined that the owner and electronics trading company attempted to reexport items from the UAE to Syria on two occasions and did reexport items from the UAE to Syria and Iran on 11 occasions without the required BIS licenses.
  • The owner also provided false or misleading information about reexports to Syria to the export control officer.
  • The charging letter sets forth 14 violations by the owner and the electronics trading company involving these activities. 

*A charging letter is merely the means by which administrative enforcement proceedings are initiated pursuant to the EAR, and the respondent is entitled to contest the violations and allegations therein, as part of the adjudicative procedures set forth in Part 766 of the regulations. Administrative enforcement proceedings under the EAR currently are adjudicated by administrative law judges employed by the U.S. Coast Guard.

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com

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