Last week the Bureau of Industry and Security (“BIS”) issued a press release, announcing a $40,000 fine that Ram International, a St.-Louis-based freight forwarder, had agreed to pay in connection with two exports of tin scrap to Allied Trading Company in Karachi, Pakistan. Allied is on BIS’s entity list, and a license is required for all exports of items to Allied from the United States. There is, however, a presumption of approval for licenses for EAR99 items such as the tin scrap involved in this case. Neither he press release nor the charging documents disclose the value of the tin scrap that Ram exported.

Not all BIS export settlements have the honor of agency press releases announcing the settlements. It’s not clear why this relatively small settlement was made the subject of a press release other than, perhaps, to send a signal to freight forwarders the BIS is actively pursuing cases not only against the exporting companies but also against their freight forwarders, particularly where the freight forwarder hasn’t bothered to consult the BIS entity list prior to exporting. This should encourage freight forwarders to spend the, oh, five seconds or so it takes to fire up the Internet and to check that list. I’d imagine that there is software that could do that in even less time.

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