Epstein LLC Agrees To Pay Civil Penalty To Settle Allegations That It Violated Antiboycott Provisions

The U.S. Department of Commerce today announced that Epstein, Edell, Shapiro, Finman & Lytle LLC of Rockville, Maryland, agreed to pay a $17,000 civil penalty to settle allegations that it violated the antiboycott provisions of then Export Administration Regulations (EAR).

The Commerce Department's Bureau of Industry and Security (BIS) alleged that in February of 2002, in connection with transactions involving the transfer of information from the United States to Syria, Epstein furnished prohibited information about another person's business relationships with Israel in violation of the EAR. BIS also alleged that Epstein failed to report in a timely manner its receipt of the request to provide such certification from an intermediary in Jordan.

The company voluntarily disclosed the transactions and cooperated fully with the subsequent investigation. Parties who may have been involved in violations of the EAR are encouraged to submit a Voluntary Self Disclosure (VSD) to BIS’ Office of Export Enforcement, as provided for in Part 764.5 of the EAR. VSDs are an important indicator of parties’ intent to bring themselves into compliance with the EAR, and may provide important BIS important information on illicit proliferation networks. A VSD is considered a ‘great weight’ mitigating factor in the settlement of BIS administrative cases.

Assistant Secretary of Commerce for Export Enforcement Darryl W. Jackson commended BIS's Office Antiboycott Compliance for its work on this investigation.

The antiboycott provisions of the EAR prohibit U.S. persons from complying with certain requirements of unsanctioned foreign boycotts, including furnishing information about business relationships with or in Israel. In addition, the EAR requires that U.S. persons report their receipt of certain boycott requests to the Department of Commerce.