BIS says voluntary disclosure ‘significantly reduced’ antiboycott penalty
The US Bureau of Industry and Security (‘US BIS’) announced 26 August that it had imposed ‘a civil penalty of $44,750 against Streamlight, Inc. (Streamlight), a global manufacturer of portable lighting products located in Eagleville, Pennsylvania, to resolve three alleged violations of the antiboycott provisions of the Export Administration Regulations (EAR).’
It said that Streamlight had ‘voluntarily self-disclosed the conduct to BIS, cooperated with the investigation by BIS’s Office of Antiboycott Compliance (OAC), and implemented remedial measures after discovering the conduct at issue, all of which resulted in a significant reduction in penalty.’
BIS said that a Proposed Charging Letter alleged that Streamlight had ‘violated the antiboycott provisions of the EAR by furnishing information about its business relationships with boycotted countries or blacklisted persons and failing to report the receipt of a request to engage in a restrictive trade practice or foreign boycott against a country friendly to the United States,’ and that, specifically, it had ‘participated in a trade show in Bahrain in 2019 [and that] in connection with the shipment of goods for display at the trade show, the company furnished to its freight forwarder/logistics provider a commercial invoice/packing list certifying that the goods were not of Israeli origin and not manufactured by a company on the “Israeli Boycott Blacklist.”’
Assistant Secretary for Export Enforcement Matthew S. Axelrod said, ‘When, as here, a freight forwarder asks you to certify that “no labor, capital, parts or raw materials of Israeli origin have been used in the printing, publishing or manufacture of these goods,” the right response is to decline and to report the request – otherwise, there will be consequences.’
