Deemed Export Regulations: Punishment

The EAR and ITAR subject violators to separate fines for violations, which – depending on criminal or civil liability – can run up to $1M or $250K per violation, respectively.  How does this work?


Suppose that (without a license) you accidentally send design documents for controlled technology to a foreign client.  It was a mistake, but you sent three different design documents for three different controlled technologies.  Given that the disclosure was a mistake, the violation will likely only subject you to civil penalties.  There were three violations, so in total, you could potentially be subject to $750K in fines for one mistaken disclosure.


Though compliance is complex – and often expensive – there are substantial penalties associated with non-compliance.  You must make proper efforts to invest in compliance to ensure that you and your firm do not violate relevant deemed export regulations.

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