U.S. BIS issues penalties and settlements for export violations
Violations of the Export Administration Regulations
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October 1, 2025
The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today released two separate orders addressing violations of the Export Administration Regulations (EAR) by different entities.
- BIS has penalized a company incorporated in the British Virgin Islands and its beneficial owner for the unlicensed reexport of a Bombardier Global 7500 aircraft to Russia. The violation occurred on March 12, 2022, when the aircraft, containing more than 25% U.S.-manufactured parts, was flown from the Maldives to Russia without the required BIS license, contravening Section 746.8 of the EAR. The aircraft remained in Russia for 25 days, exceeding the 14-day limit for a temporary sojourn under the AVS License Exception, thus necessitating a license. The company and beneficial owner admitted to the violation and were assessed a civil penalty of $374,474, payable within 30 days, with compliance required to maintain export privileges. Read the BIS order
- BIS reached a settlement agreement with a Canadian company to resolve allegations that the company violated the EAR by exporting items subject to the EAR to an end user in Iran without the required authorization on October 21, 2022. The company exported three PhotonMaster luminometers and 25 aqueous test kits, categorized as EAR99 items, which required authorization for export to Iran. The Canadian company, with a production facility in Linthicum Heights, Maryland, exported the items to a Tehran-based distribution company via a Dubai-based freight forwarder, engaging in deceptive practices to conceal the true end user and destination. The company admitted to the alleged conduct and agreed to a settlement with BIS, including a civil penalty of $685,051, an export compliance audit by March 30, 2026, and mandatory export compliance training for all employees within 12 months. The company is also subject to a suspended three-year denial of its export privileges, contingent on compliance with the agreement terms. Read the BIS order