Massachusetts-based New England Trading Global Inc. (“NET Global”) recently agreed to pay to the Bureau of Industry and Security (“BIS”) a $365,000 suspended penalty in connection with thirteen unlicensed exports of sodium cyanide and potassium cyanide worth $242,779 without a license to Israel. The fine was suspended on condition that the company not engage in any export violations for a period of one year. According to the settlement documents, the company voluntarily disclosed the exports to BIS.

Sodium cyanide and potassium cyanide are classified as ECCN 1C350.d.17 and 1C350.d.12 respectively. Given the legendary toxicity of both substances, this should come as a surprise to no one, particularly to a company that sells chemicals. So one can only speculate how NET Global wound up shipping more than 100 tons of cyanide without a license. Whatever happened, it had to be, at best, a massive failure to implement compliance procedures and the company should thank its lucky stars that the penalty in this case was conditionally suspended.

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