In the Matter of: Alexander Brazhnikov, Jr., Respondent; Final Decision and Order

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 No. 19-BIS-0001] This matter is before me upon a Recommended Decision and Order on Sanction (“Sanction RDO”) of an Administrative Law Judge (“ALJ”). On January 26, 2021, the ALJ referred the Sanction RDO to me pursuant to 15 CFR 766.17(b)(2) . In the Sanction RDO, the ALJ found that Respondent Alexander Brazhnikov, Jr. (“Respondent”) violated 15 CFR 764.2(d) by conspiring with others to violate the Export Administration Regulations (currently codified at 15 CFR parts 730-774 ) (“EAR” or “Regulations”) by exporting regulated items to Russian End-Users on the Entity List without the required licenses. The ALJ recommended that a denial of export privileges for 15 years be assessed against Respondent. For the reasons set forth below, I affirm the Sanction RDO and issue the attached Order imposing sanction. As described in further detail below, on April 21, 2020, in this same case, the ALJ issued an Order Partially Granting Motion for Summary Decision (“Summary Decision Order”) in which he found that Respondent had violated the EAR. The ALJ attached the Summary Decision Order to the ( printed page 13877) Sanction RDO. I affirm the Summary Decision Order as well. I. Background A. Respondent's Criminal Conviction On June 11, 2015, Respondent pled guilty to a three-count Criminal Information in the U.S. District Court for the District of New Jersey. C…