BIS Undersecretary Vacates Administrative Law Judge’s $31 Million Civil Monetary Penalty for Iran Export Controls Violations; Remands for Further Consideration
*The title of this post has been corrected to clarify the BIS Undersecretary’s decision.
In an unusual decision, the Undersecretary for the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) remanded a civil penalty of $31,425,760 assessed by an Administrative Law Judge (“ALJ”) against Nordic Maritime Pte. Ltd., (“Nordic Maritime”) a Singapore-based marine seismic company and its chairman for violations of the Export Administration Regulations (“EAR”). While agreeing with the seriousness of the…
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