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Don’t let this happen to you

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DON’T LET THIS HAPPEN TO YOU!

G

EXPORT ENFORCEMENT

G

CHAPTER 4

E.H. Wachs

South Pars Project: A Natural Gas Field Project in Iran.

The Violation: Between March 1996 and February
1997, E.H. Wachs conspired to export pipe cutting
machines and spare parts to the National Iranian Gas
Company without the required authorization. Wachs split
orders for more than fifty pipe-cutting machines and
spare parts into small shipments and then exported the
items through Canada to conceal the fact that they were
destined for Iran.

The Penalty: In the criminal case, Wachs was sentenced to a criminal fine of $506,000 and 24 months of
probation. In the administrative case, Wachs agreed to pay an administrative penalty of $159,000 and was
ordered to institute an export compliance program. Wachs also paid another administrative penalty of $85,000
to OFAC for the violations of Treasury regulations that stemmed from the unauthorized exports.

Oerlikon
The Violation: Between June 1999 and March 2000, Oerlikon Schweisstechnik AG and Reweld AG
conspired to purchase 30,000 pounds of Solka-Flok 200 cellulose, valued at $21,000, for resale and
transshipment to Iran. Oerlikon solicited Reweld to export the cellulose to Switzerland, where Oerlikon
intended to take possession of the materials and reexport them to Iran.
The Penalty: Oerlikon agreed to pay a $33,000 administrative penalty. Reweld agreed to pay a $22,000
administrative penalty. In addition, Oerlikon agreed to a one year denial of export privileges. The denial of
export privileges was suspended.

Industrial Scientific Corporation
The Violation: Industrial Scientific Corporation (ISC) violated the EAR by shipping two gas monitors from
the United States to the United Arab Emirates in June 1998 without obtaining the proper authorization from
the U.S. Government. In addition, ISC further violated the EAR by transferring the gas monitors to the UAE
with knowledge that the monitors would be re-exported from the UAE to Iran.
The Penalty: ISC agreed to pay a $30,000 administrative penalty.

19

DON’T LET THIS HAPPEN TO YOU!

EXPORT ENFORCEMENT

G

G

CHAPTER 5

Chapter 5 - Transshipment and Re-exports
Introduction

P

arties to an export transaction cannot bypass the EAR by shipping items through a third country. The
transshipment, re-export, or diversion of goods and technologies in international commerce may be a
violation of U.S. law. For example, an exporter cannot bypass the U.S. embargo against Iran by shipping
an ite...
E.H. Wachs
The Violation: Between March 1996 and February
1997, E.H. Wachs conspired to export pipe cutting
machines and spare parts to the National Iranian Gas
Company without the required authorization. Wachs split
orders for more than fifty pipe-cutting machines and
spare parts into small shipments and then exported the
items through Canada to conceal the fact that they were
destined for Iran.
The Penalty: In the criminal case, Wachs was sentenced to a criminal fine of $506,000 and 24 months of
probation. In the administrative case, Wachs agreed to pay an administrative penalty of $159,000 and was
ordered to institute an export compliance program. Wachs also paid another administrative penalty of $85,000
to OFAC for the violations of Treasury regulations that stemmed from the unauthorized exports.
Oerlikon
The Violation: Between June 1999 and March 2000, Oerlikon Schweisstechnik AG and Reweld AG
conspired to purchase 30,000 pounds of Solka-Flok 200 cellulose, valued at $21,000, for resale and
transshipment to Iran. Oerlikon solicited Reweld to export the cellulose to Switzerland, where Oerlikon
intended to take possession of the materials and reexport them to Iran.
The Penalty: Oerlikon agreed to pay a $33,000 administrative penalty. Reweld agreed to pay a $22,000
administrative penalty. In addition, Oerlikon agreed to a one year denial of export privileges. The denial of
export privileges was suspended.
Industrial Scientific Corporation
The Violation: Industrial Scientific Corporation (ISC) violated the EAR by shipping two gas monitors from
the United States to the United Arab Emirates in June 1998 without obtaining the proper authorization from
the U.S. Government. In addition, ISC further violated the EAR by transferring the gas monitors to the UAE
with knowledge that the monitors would be re-exported from the UAE to Iran.
The Penalty: ISC agreed to pay a $30,000 administrative penalty.
DON’T LET THIS HAPPEN TO YOU!
EXPORT ENFORCEMENT
CHAPTER 4
19
South Pars Project: A Natural Gas Field Project in Iran.
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