The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 14 Jun 2024 - USGoBuy, LLC - Denial Order; USD $15,000
On June 14, 2024, BIS activated the $15,000 suspended portion of the civil penalty and the suspended three-year denial order imposed against USGoBuy, LLC (“Respondent”) in BIS’s June 17, 2021, order (“Order”) approving the terms of the June 16, 2021, settlement agreement (“Settlement Agreement”) between BIS and Respondent. BIS activated the suspended penalty amount and the suspended denial order because the Respondent violated the probationary conditions of the Order by (i) failing to implement certain corrective actions in response to the underlying violations that led to the Settlement Agreement and Order; (ii) committing additional violations of the Export Administration Regulations (“EAR”) during the three-year probationary period of the Order; and (iii) failing to implement corrective actions to address those additional violations. See E2668 for additional information.
- 24 Jun 2024 - Indiana University - Denial Order; No monetary penalty
On June 24, 2024, Indiana University (“Respondent”) agreed to a suspended one-year denial order as part of a Settlement Agreement with BIS in connection with violations of section 742.2(a) of the Export Administration Regulations (“Regulations”). Specifically, on 42 occasions between November 27, 2017 and April 29, 2021, the Respondent exported (without authorization) to 16 countries various strains of genetically modified fruit flies containing transgenes of the A subunit of the ricin toxin, which are classified under Export Control Classification Number (ECCN) 1C353. All 16 destinations to which Respondent exported these fruit fly strains were listed under the Chemical and Biological Weapons category of the Commerce Country Chart and therefore required a license for export. Respondent submitted a voluntary self-disclosure to BIS in accordance with section 764.5 of the Regulations.
- 11 Jul 2024 - Robert Wise - Denial Order; No monetary penalty
On July 11, 2024, BIS issued a denial order against Robert Wise (“Respondent”) for a period of 5 years in relation to violations of 18 U.S.C. § 371. The order went into effect on the Respondent’s date of conviction on December 4, 2023. Specifically, the Respondent was convicted of conspiring to commit international money laundering by using international wire transfers to conduct U.S. dollar transactions for a sanctioned Russian oligarch. The Respondent was sentenced to time served, two years of supervised release, and a $100,000 fine. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalties.
- 11 Jul 2024 - Ruben Arnulfo Chavarin - Denial Order; No monetary penalty
On July 11, 2024, BIS issued a denial order against Ruben Arnulfo Chavarin (“Respondent”) for a period of 10 years in relation to violations of 18 U.S.C. § 544(a). The order went into effect on the Respondent’s date of conviction on April 9, 2021. Specifically, the Respondent was convicted of smuggling ammunition from the United States to Mexico. The Respondent was sentenced to seventy-eight months of imprisonment, with credit for time served, three years of supervised release, a $100 special assessment and additional monetary penalties of $10,307.20. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalties.
- 11 Jul 2024 - Charles McGonigal - Denial Order; No monetary penalty
On July 11, 2024, BIS issued a denial order against Charles McGonigal (“Respondent”) for a period of 10 years in relation to violations of 18 U.S.C. § 371. The order went into effect on the Respondent’s date of conviction on December 14, 2023. Specifically, the Respondent was convicted of conspiring to violate U.S. sanctions against Russia by going to work for a Russian oligarch whom he once investigated. The Respondent was sentenced to fifty months imprisonment, three years of supervised release, a $100 special assessment and a fine of $40,000. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalties.
- 11 Jul 2024 - Melanie Ann Espinoza - Denial Order; No monetary penalty
On July 11, 2024, BIS issued a denial order against Melanie Ann Espinoza (“Respondent”) for a period of 7 years in relation to violations of 18 U.S.C. § 544(a). The order went into effect on the Respondent’s date of conviction on August 26, 2021. Specifically, the Respondent was convicted of smuggling thousands of rounds of ammunition. The Respondent was sentenced to nine months of imprisonment, with credit for time served, three years of supervised release, and a $100 special assessment. BIS did not impose further monetary penalty on Respondent beyond the Court-imposed penalties.
- 13 Aug 2024 - Nicolas Ayala - No Denial Order; No monetary penalty
On August 13, 2024, BIS issued an amendment to a September 6, 2023 Denial Order against Nicholas Ayala (“Respondent”). BIS amended the Denial Order by correcting the spelling of the Respondent’s name to "Nicolas Ayala" in the caption and text of the Denial Order. Additionally, BIS amended the address on the Denial Order by deleting “Inmate Number: 97331-509, FCI Edgefield, P.O. Box 725, Edgefield, SC 29824” and adding Respondent's current last known address: “25 NE Fifth Street Apt 1720, Miami, FL 33132”. In all other aspects, the September 6, 2023 Denial Order remains in full force and effect. See E2892 for more details on the September 6, 2023 Denial Order.
- 13 Aug 2024 - Rami Najm Ghanem - Denial Order; No monetary penalty
On August 13, 2024, BIS issued a Denial Order against Rami Najm Ghanem (“Respondent”) for a period of 10 years in relation to violations of 18 U.S.C. § 371, 18 U.S.C. § 554, and Section 38 of the Arms Export Control Act (22 U.S.C. § 2778). The Order went into effect on the Respondent’s date of conviction on October 31, 2022. Specifically, the Respondent was convicted of having knowingly and willfully engaged in weapons brokering activities without the required licenses, and of negotiating and arranging contracts, purchases, sales, and transfers of defense articles, foreign defense articles, defense services, and foreign defense services, including for machine guns. BIS did not impose any monetary penalty.
- 13 Aug 2024 - Marco Antonio Peralta-Vega - Denial Order; No monetary penalty
On August 13, 2024, BIS issued a Denial Order against Marco Antonio Peralta-Vega (“Respondent”) for a period of 10 years in relation to violations of 18 U.S.C. § 554(a). The Order went into effect on the Respondent’s date of conviction on August 18, 2021. Specifically, the Respondent was convicted of smuggling various firearms and ammunition from the United States to Mexico. The Respondent was sentenced to 36 months in prison with credit for time served, three years of supervised release, and a $100 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalties.
- 13 Aug 2024 - Yi-Chi Shih - Denial Order; No monetary penalty
On August 13, 2024, BIS issued a Denial Order against Yi-Chi Shih (“Respondent”) for a period of 10 years in relation to violations of 50 U.S.C. § 1705 and 18 U.S.C. § 1001. The Order went into effect on the Respondent’s date of conviction on November 17, 2023. Specifically, the Respondent was convicted of knowingly and willfully exporting Monolithic Microwave Integrated Circuits (MMICs) from the United States to China without the required licenses. The Respondent also made false statements to federal agents. BIS did not impose any monetary penalty.
- 13 Aug 2024 - Kenan L’Homme - Denial Order; No monetary penalty
On August 13, 2024, BIS issued a Denial Order against Kenan L’Homme (“Respondent”) for a period of 6 years in relation to violations of 18 U.S.C. § 554(a). The Order went into effect on the Respondent’s date of conviction on November 28, 2022. Specifically, the Respondent pleaded guilty to willfully and knowingly attempting to export from the United States various firearms and firearm components. The Respondent was sentenced to 36 months in prison and a $200 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalties.
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