WorldECR | BIS says voluntary disclosures are “significant”

The U.S. Bureau of Industry and Security (“US BIS”) announced on August 26 that it has imposed a $44,750 civil penalty on Streamlight, Inc. (Streamlight), a global manufacturer of portable lighting products located in Eagleville, Pennsylvania, to resolve three alleged violations of the anti-boycott provisions of the Export Administration Regulations (EAR).

The court said Streamlight “voluntarily disclosed the conduct to BIS, cooperated with the BIS Office of Antiboycott Compliance (OAC) in its investigation, and implemented remedial measures after discovering the conduct, all of which resulted in a significant reduction in the penalty.”

BIS said a proposed charging letter alleges Streamlight “violated the antiboycott provisions of the EAR by providing information about business relationships with boycotted countries or blacklisted persons without reporting requests for restrictive trade practices or foreign boycotts against countries friendly to the United States,” specifically that the company “participated in a trade show in Bahrain in 2019, (and) when shipping goods for display at the trade show, the company provided its freight forwarder/logistics provider with a commercial invoice/packing list certifying that the goods were not of Israeli origin or produced by a company on the ‘Israel Boycott Blacklist.’”

“When a freight forwarder asks you to certify that ‘no Israeli-origin labor, capital, parts, or raw materials were used in the printing, publishing, or manufacturing of these goods,’ the correct response is to deny and report the request — or there will be consequences,” said Matthew S. Axelrod, assistant secretary for export enforcement.