On or about January 23, 2010, April 6, 2010, and May 14, 2010, Trilogy International Associates, Inc., of Altaville, CA exported an explosives detector and a total of 115 analog-to-digital converters to Russia. These items are subject to the EAR and controlled on national security grounds. The items were classified under Export Control Classification Numbers 1A004 and 3A001, respectively, and valued in total at approximately $76,035. Each of the items required a license for export to Russia pursuant to Section 742.4 of the EAR.
Between, on, or about January 20, 2010 and May 14, 2010, William Michael Johnson of Angels Camp, CA, caused, aided, and/or abetted three violations of the EAR, specifically three exports from the United States to Russia of items subject to the EAR without the required BIS export licenses.
Charges include:
- Three Charges of 15 C.F.R. § 764.2(a) – Engaging in Prohibited Conduct
- Three charges of 15 C.F.R. § 764.2(b) – Causing, Aiding, or Abetting a Violation
Penalty:
- Civil penalty of $100,000 against Trilogy International Associates, Inc.
- Civil penalty of $100,000 against William Michael Johnson
- Debarred: Both Trilogy International Associates, Inc. and William Michael Johnson are denied export privileges for a period of 10 years from the date of this Order, until 26 February 2028.
Date of Order: 26 February 2018
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