BIS Imposes Civil Penalties on U.S. Company and its German Affiliate for Violations Related to Exports of Thermal Imaging Cameras
The Bureau of Industry and Security (BIS) has imposed civil penalties on E.D. Bullard Co. (Bullard) and its German affiliate, Bullard GmbH (Bullard Germany), for reselling, reexporting or transferring thermal imaging cameras to Austria, France and Switzerland. Bullard is a leading manufacturer of personal protective equipment and systems that are marketed worldwide. The thermal imaging cameras sold by Bullard are classified as ECCN 6A003.b.4 and require an export license to be shipped to many countries.
In its charging letter, BIS alleged that Bullard committed 55 violations of the Export Administration Regulations (EAR) related to the export of thermal imaging cameras. For example, BIS alleged that Bullard exported thermal imaging cameras to Israel without a license; exported thermal imaging cameras in excess of the quantities specified in the licenses; violated license conditions specified in the export licenses by reselling, reexporting or transferring the cameras to destinations not specified in the licenses; exported thermal imaging cameras to an intermediate consignee not authorized by the license; exported thermal imaging cameras after the expiration date of the license; and making false statements on numerous export Shipper's Export Declarations. In addition, BIS alleged that Bullard Germany violated license conditions specified in the export licenses by reselling, reexporting or transferring the cameras to destinations not specified in the export licenses that it had obtained.
Bullard entered into a settlement agreement with BIS which provided that Bullard would pay a $330,000 civil penalty to Commerce Department. The settlement agreement also specifies that Bullard must perform an internal audit of its internal export compliance and provide a copy of the internal audit to BIS's Office of Export Enforcement. The settlement agreement entered into by Bullard Germany requires the company to pay a $36,000 civil penalty to the Commerce Department.
The charging letters, settlement agreements and orders in these cases can be found at the following links:
http://efoia.bis.doc.gov/ExportControlViolations/E895.pdf (Bullard GmbH)
http://efoia.bis.doc.gov/ExportControlViolations/E896.pdf (E.D. Bullard)
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