BIS Imposes $82,500 Penalty on Zoll Medical Corporation for Making Unlicensed Exports to Iran
In the latest enforcement case involving a medical device company and the second recent case involving South Africa as a transshipment point, the Commerce Department's Bureau of Industry and Security (BIS) recently imposed a penalty of $82,500 on Zoll Medical Corporation (Zoll), a Massachusetts-based manufacturer and seller of cardiac defibrillators and other cardiac-related medical devices, for making unlicensed sales of cardiac defibrillators to Iran.
According to the charging letter and settlement agreement, BIS alleged that Zoll committed 10 violations of the Export Administration Regulations (EAR). Specifically, BIS alleged that Zoll committed two violations of the EAR by making two shipments in 2000 of cardiac defibrillators to Iran, via South Africa, without the required export licenses. BIS also alleged that Zoll knowingly committed two violations of the EARs since the company knew or had reason to know that the products would be exported to Iran. In addition, BIS contended that Zoll made false statements on the Shipper's Export Declarations filed in connection with the shipments, by misrepresenting the ultimate destination of the products, inaccurately stating the ultimate consignee of the goods and incorrectly specifying that the goods qualified for export from the U.S. as NLR (no license required).
Earlier this year, Asher Karni, an Israeli national residing in Capetown, South Africa, pled guilty in connection with a scheme to export oscilloscopes and triggered spark gaps from the U.S. to Pakistan, via South Africa.
The charging letter, settlement agreement and Order issued by BIS in the Zoll Medical case can be viewed at the following link: http://efoia.bis.doc.gov/ExportControlViolations/E906.pdf.
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