BIS reached its first settlement under the new policies announced last month.
BIS reached its first settlement under the new policies announced last month. The respondent received non-monetary penalties because he admitted to the illegal conduct. This settlement still resulted in a two-year suspended denial of export privileges. BIS is also requiring the respondent to implement compliance training and perform a twelve-month audit of the company's export compliance program. BIS will seek to resolve administrative enforcement actions with non-monetary penalties in relatively less serious matters, but targets of these enforcement actions will need to accept responsibility for the illegal conduct and agree to remedial measures.