By Timothy F. Hubach
The Bureau of Industry and Security (BIS) recently imposed a $221,250 civil penalty on Massachusetts-based Hittite Microwave Corporation for allegedly participating in sales of controlled microwave solid state amplifiers and related equipment, including downconverters, from the United States to Russia, China and Latvia. The products are classified as ECCNs 3A001.b.2 and 3A001.b.4 on the Commerce Control List.
In its charging letter, BIS claimed that Hittite committed six violations of the Export Administration Regulations (EAR). BIS alleged that Hittite transferred the microwave equipment without obtaining the proper licenses from the Department of Commerce as required by the EAR. BIS also claimed that Hittite made a false statement on the ShipperÂs Export Declaration (SED) since the SED stated that the export of the downconverters qualified for export from the United States under license exception "GBS" (i.e., Country Group B). However, Latvia was not in Country Group B at the time of export.
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