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May 17, 2004 

BIS Imposes $24,500 Penalty for Antiboycott Violations

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has imposed a $24,500 civil penalty on Input/Output Exploration Products (UK), Inc., the foreign subsidiary of a Texas-based U.S. manufacturer of seismic imaging technology, to settle charges that the company violated the antiboycott provisions of the Export Administration Regulations (EAR).

In its charging letter, BIS alleged that in 1999 Input/Output Exploration Products (UK), Inc., violated the EAR when it provided answers to questions from a customer about its business with or in Israel and the business relationships of its parent company with or in Israel. BIS also charged that in 1999 Input/Output Exploration Products (UK), Inc. unlawfully agreed to refuse to do business with companies on lists maintained by Arab League countries that boycott Israel, and failed to report its receipt of boycott requests received in three transactions. The charges involved transactions with Syria, which the company voluntarily self-disclosed to BIS.

The antiboycott provisions of the EAR prohibit U.S. persons from complying with certain
requirements of unsanctioned foreign boycotts, including providing information about business relationships with Israel and refusing to do business with persons on boycott lists. In addition, the EAR requires that persons report their receipt of certain boycott requests to the Department of Commerce. Under the antiboycott provisions of the EAR, a controlled-in-fact foreign subsidiary of a domestic U.S. company is considered a U.S. person.

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