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March 23, 2006 

BIS Imposes Civil Penalty on Ohio Company for Exporting Controlled Software to Organization on Entity List

The Bureau of Industry and Security (BIS) has imposed a $7,000 civil penalty on Tech Pro, Inc., an Ohio-based manufacturer of laboratory testing instruments for the rubber and plastics industries, for exporting software to a party in India on the BIS Entity List. Specificallly, BIS alleged that Tech Pro exported software upgrades classified under ECCN 4D994 to the Vikram Sarabhai Space Center of Thiruvanthapuram, India, an organization on the Department of Commerce’s Entity List, without obtaining an export license.

BIS established the Entity List in February 1997 to inform the public of entities whose activities imposed a risk of diverting exported and reexported items into programs related to weapons of mass destruction. The grounds for listing an entity on the Entity List have expanded to include entities sanctioned by the State Department for which U.S. foreign policy goals are served by imposing additional license requirements on exports and reexports. U.S. exporters should screen all of their customers against the Entity List.

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