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U.S. BIS imposes three-year export ban on U.S. package forwarding company for continued violations of EAR

Continued violations of the Export Administration Regulations (EAR) and failure to address past compliance failures.

June 18, 2024

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce has issued a three-year denial order against a package forwarding company based in Portland, Oregon.

According to the BIS release (June 17, 2024), this prohibits the package forwarding company from participating in all exports under BIS jurisdiction from the United States. The denial order was activated due to continued violations of the Export Administration Regulations (EAR) and failure to address past compliance failures.

Originally, this denial order was a suspended penalty included in a 2021 settlement agreement with the package forwarding company, which resolved previous alleged violations involving unlicensed exports of riflescopes to China and the United Arab Emirates. As part of the settlement, the package forwarding company was required to conduct an audit of its export control compliance program. The audit revealed significant deficiencies and additional violations, including failures in filing Electronic Export Information and maintaining adequate records. Despite these findings, the package forwarding company did not implement the necessary corrective actions.

The order denies the package forwarding company all export privileges described in section 764.3(a)(2) of the EAR, which includes applying for, obtaining, or using any license, license exception, or export control document.

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
Principal
E: ivaysfeld@kpmg.com
Amie Ahanchian
Principal
E: aahanchian@kpmg.com
Christopher Young
Principal
E: christopheryoung@kpmg.com
Gisele Belotto
Principal
E: gbelotto@kpmg.com
George Zaharatos
Principal
E: gzaharatos@kpmg.com
Andy Doornaert
Managing Director
E: adoornaert@kpmg.com
Jessica Libby
Principal
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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