Key Lessons From a Recent Export Enforcement Case Against a U.S. Pharmaceutical and Medical Supply Company 

The BIS imposed a civil penalty of $8.1 million for the EAR violations, and OFAC imposed $7.6 million in civil penalties for violations of the sanctions on Iran, Sudan and Syria.  

An interesting point in this case is the fact that the company could have applied for and obtained the required authorizations for the shipments to all three countries under the Trade Sanctions Reform Act (“TSRA”). Peculiarly, the company had previously obtained TSRA authorizations for exports of similar products to sanctioned countries. 

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