Yes, the U.S. Department of Commerce, Bureau of Industry and Security may have been shut down from December 20th 2018 until it re-opened this past Monday, but that did not stop Export Enforcement from levying an $US 80,000 charging letter and invoice to Ithaca, New York based Multiwire Laboratories, Ltd. for its failure to take five minutes out of its business day back in February 2014 and August 2015 when on two occasions it exported two Real Time Back Reflection Laue Cameras valued at $177,156 to the University of Electronic Science and Technology (“USETC”) of China based in Chengdu. Problem was, Multiwire had no export compliance screening (a five-minute routine procedure) that would have red lighted the transaction due to USETC being listed on the BIS Entity List (Supplement 4 to Part 744 of the EAR). An expensive mistake indeed. Lesson learned. Run a Consolidated List screen on EVERY transaction at time of inquiry/sale and again just-in-time prior to export. Please contact TSI Global Consulting for more details and training on how to properly screen potential buyers against U.S. government denied parties lists. Don’t let a 5-minute short cut cost you $80K…..
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