U.S. Bureau of Industry and Security, Office of Foreign Assets Control Impose Fines on Texas Manufacturer and Its Foreign Affiliates for Unlawful Exports

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An enforcement action announced by the U.S. Commerce Department's Bureau of Industry and Security (BIS) on September 15 has provided another reminder that all exports of items, software or commodities from the U.S. are subject to the U.S. Export Administration Regulations, whether or not the item is specifically classified under the U.S. Commerce Control List. This case also demonstrates the importance of frequent training and internal auditing of export compliance – simply having a compliance policy in place may not prevent violations.

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