Comments on: BIS Continues to Stack Deck Against Voluntary Disclosures

By: ExportLawBlog » Magnetic Shield Corporation — Update

ExportLawBlog » Magnetic Shield Corporation — Update — Wed, 28 Feb 2007 15:48:53 +0000

[...] The prior post “BIS Continues to Stack Deck Against Voluntary Disclosures” has been updated and revised to reflect the fact that there were two transactions, not one, involved in that case. Permalink No Comments [...]

By: exportattorney

exportattorney — Wed, 28 Feb 2007 01:33:34 +0000

By my read of the charging letter and settlement agreement, these involved two different transaction (check the dates in the charging letter again).

By: Ladyx

Ladyx — Tue, 27 Feb 2007 19:10:06 +0000

So, you take 2 ounces of “stupid” violation, add 1 ounce of “clerical error” and 1 ounce of BIS “strong arming” and you get one hell of an “Export VSD Cocktail”!!! Other than the obvious fine of $19,000, can you imagine the monies spent on an internal audit prior to disclosure? Where was outside counsel? I simply fail to understand why any company would voluntarily self-disclose a violation that ocurred 6 years ago, especially if they had all of their “ducks” in a row, unless there is something more to the story.

By: Andrew

Andrew — Tue, 27 Feb 2007 15:17:53 +0000

Another great example why it sometimes doesn’t pay to be too compliant and forthcoming with a VSD.