Export Enforcement Highlights from Commerce/BIS Regulations and Procedures Technical Advisory Committee Meeting

At the December 5, 2006 meeting of the Regulations and Procedures Technical Advisory Committee, the following enforcement issues were discussed:

1. The increase in boycott requests from Iraq and Libya. Since power has transferred from the Coalition Provisional Authority to the new Iraqi government, boycott requests there have increased significantly since falling in 2004. Closing the Libyan boycott compliance office has resulted in increased requests from Libya as well. The biggest of the boycotting countries is U.A.E.
2. The Office of Export Enforcement reported that one of their highest priorities is the renewal of the Export Administration Act (EAA). Proposed changes for the act upon renewal include penalties increased from $11,000 to $50,000 as well as imposing criminal penalties for violations. They will continue to encourage Voluntary Self-disclosures (VSDs) with the policy that penalties will be reduced by 50% with the option to consider other factors which could reduce penalties even further. From 2004-2006 only 5% of VSDs resulted in any penalty at all. Half of the other 95% resulted in the conclusion that no violation had occurred.