Commerce Department, Industry and Security Bureau
Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of Commerce Bureau of Industry and Security [Docket Number 17-BIS-0004 (consolidated)] This matter is before me to review the Administrative Law Judge's (ALJ) February 7, 2020 Recommended Decision and Order (RDO). [ 1 ] For the ( printed page 15415) reasons discussed below, and upon review of the administrative record, I find there is sufficient evidence that Nordic Maritime Pte. Ltd. (Nordic) and Morten Innhaug (Innhaug and, collectively, Respondents) violated the Export Administration Regulations (EAR), [ 2 ] that Nordic did so knowingly, and that Nordic made false statements to the Bureau of Industry and Security (BIS) in the course of its investigation. I further find that the evidence supports the conclusion that Innhaug caused, aided, or abetted Nordic's unlawful reexport of the survey equipment in violation of EAR. The ALJ recommended a civil monetary penalty of $31,425,760, as well as a denial of export privileges until such time Respondents pay the civil monetary penalty. With respect to the RDO's monetary penalty recommendation, I conclude the analysis of damages in the RDO is incomplete. For the following reasons, I affirm the findings of liability, modify the denial order to a period of 15 years, and vacate the civil monetary penalty, and remand this case to the ALJ for a reexamination of the civil monetary penalty. I. Background  [ 3 ] BIS issued a charging letter to Respondent Nordic on April 28, 2017, alleging three violations of the EAR: (i) …
Other Federal Register documents from the same docket.
Citation: 85 FR 15414
