BIS Imposes $108,000 Penalty on Houston Freight Forwarder for Violating Antiboycott Regulations
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has announced that the Houston, Texas operations of Rohde & Liesenfeld, Inc., a German-based freight forwarder that has since been aquired by another freight forwarding company, agreed to pay a $108,000 civil penalty to settle allegations that it violated the antiboycott provisions contained in Part 760 (15 CFR Part 760) of the Export Administration Regulations (EAR).
BIS's Office of Antiboycott Compliance, alleged that, on 36 occasions during 2002 and 2003, the freight forwarder, in connection with transactions involving the sale and transfer of goods from the U.S. to Syria, furnished prohibited information about its or another company’s business relationships with or in a boycotted country.
Based on the dates of the alleged violations and the fact that penalty amount was $3,000 per violation, this case appears to have been brought under the previous penalty threshold of $11,000 per violation. As of this writing the proposed Charging Letter and Settlement Agreement have not been issued so it is uncertain if these alleged violations were voluntarily disclosed or not.