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May 04, 2008 

BIS Imposes $31,500 Penalty on California Company For Violating Deemed Export Rule

The Commerce Department's Bureau of Industry and Security (BIS) recently imposed a $31,500 penalty on TFC Manufacturing Inc., a Lakewood, California-based aerospace fabrication facility, for violating the "deemed export" rule.

According to the Settlement Agreement and Proposed Charging Letter, BIS alleged that between March and April 2006, TFC engaged in the unlicensed released in the U.S. of technology for the production of aircraft parts (classified under ECCN 9E991) to an employee who was a national of Iran. Pursuant to the deemed export rule in section 734.2(b)(ii) of the Export Administration Regulations (EAR), the release of technology to a national of Iran is deemed to be the export of the technology to Iran and is prohibited without a license.

This penalty was imposed under the increased penalty provisions of the IEEPA Enhancement Act.

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