The Bureau of Industry and Security (“BIS”) has issued a temporary denial order against everyone in sight involved in the Cirrus Electronics matter. As we previously reported, Cirrus Electronics took orders for electronic components from the Vikram Sarabhai Space Centre (”VSSC”) and Bharat Dynamics, Ltd (”BDL”) both Indian-government related companies on the Entity List.

Cirrus would then use a U.S. subsidiary to source these parts from U.S. vendors. The U.S. subsidiary would then ship the components to Cirrus in Singapore which would then ship the components to VSSC and BDL without obtaining the licenses required by BIS for exports to parties on the Entity List. When the U.S. vendors requested end-use statements for the parts being sold to Cirrus, Cirrus would lie to them and claim that the parts were destined for the Navy Physical and Oceanographic Laboratory in Kochi, India.

The temporary denial order, not surprisingly, emphasized the false end-use reports to the U.S. vendors as proof that Cirrus and its principals had knowledge that exports to VSSC and BDL required licenses. For those who think that this blog criticizes everything that BIS does, we state — for the record — that if the allegations in the TDO are true, Cirrus and its principals got what they deserved.

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