Comments on: Export Nickel, Pay 14 Million Nickels

By: Tatsuya Kanemitsu

Tatsuya Kanemitsu — Thu, 19 Nov 2009 00:14:00 +0000

Hello,
I always enjoy reading your blog. Thank you.

As for Singapore, although they are not a member of NSG, they implement export control with strict manner in samw way as other member states.
Singapore have controlled list and 1C240a is also listed as export license required. Please see below URL for your information.

http://www.customs.gov.sg/stgc/leftNav/str/

Thanks!

By: Clif Burns

Clif Burns — Wed, 18 Nov 2009 20:57:19 +0000

The schedule to the charging letter lists 15 shipments.

I’m sure that the knowledge issue was also a contributing factor to the size of the fine, but it was applied to only two counts, both of which involved exports while license applications were pending. I’m not so sure that this was exporting “with knowledge” as it was some administrative snafu by the company. It’s certainly not like those cases where people are told that licenses are necessary and then put a false description of the item in the AES entry and never even apply for a license.

Even with the knowledge and proliferation aspects involved it still seems a large fine. Of course, I can hear BIS saying now that it’s small in comparison to the eleventy million trillion dollar fine that they could have charged for 28 counts at $250,000 each.

By: Ann

Ann — Wed, 18 Nov 2009 20:12:48 +0000

15 unlicensed shipments? The final order lists charges 1 through 28, no? Plus knowledge counts? I would imagine the knowledge issue explains the high fine. Or at least was a factor.

By: Clif Burns

Clif Burns — Wed, 18 Nov 2009 17:17:40 +0000

Thanks, Ed. I’ve updated the post to reflect your comments.

By: Ed Fox

Ed Fox — Wed, 18 Nov 2009 16:28:57 +0000

Nickel powder is controlled by the Nuclear Suppliers Group. Russia, Canada and Australia would require an export license before it could be exported to most countries.