Commerce Fines Company for Illegal Exports, Failure to Comply With EAR Record-Keeping Requirements

A Rhode Island veterinary instrument supplier was fined $136,000 by the Commerce Department for 11 violations of the Export Administration Regulations, Commerce said in a charging letter signed Nov. 7. The company, Cotran Corp., illegally exported electric cattle prods to Venezuela, Mexico, South Africa and the Czech Republic without the required license, and did not comply with EAR record-keeping requirements, Commerce said.

Between 2011 and 2015, Cotran illegally exported $81,010 worth of the prods to the four countries on 10 occasions. Although the company had previously applied for and received “a number” of export licenses for the prods, “including to some of the destinations and end-users at issue,” Cotran did not have proper licenses for these 10 exports, Commerce said. The company did not ”properly monitor” the expiration dates for its export licenses, the charging letter said. Cotran also violated EAR record-keeping requirements by failing to retain invoices and bills of lading relating to the exports, according to Commerce.

Cotran was fined $136,000 to be paid out in installments over the next year, but Commerce agreed to waive $86,000 worth of the penalty if Cotran does not commit another violation of the Export Control Reform Act during its four-year probationary period. If Cotran does not make its payments on time, the company will be subject to further charges, the agency said. Commerce may also deny Cotran’s export privileges for two years if it does not “comply in full” with the terms of the settlement agreement.