BIS Publishes Enforcement Order for Texas Supplier's Export Violations
The Bureau of Industry and Security this week officially released its enforcement order, charging letter and settlement agreement involving Unicat Catalyst Technologies, the Texas-based industrial equipment supplier that recently was assessed millions of dollars in combined penalties by BIS, DOJ and the Office of Foreign Assets Control for allegedly violating export control and sanctions laws (see 2506170047).
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The BIS order, published June 23 and dated Dec. 20, 2024, comes less than a week after DOJ announced it wouldn’t be prosecuting Unicat’s parent company, U.K.-based private equity firm White Deer Management, which bought Unicat in 2021 and reported the violations to DOJ one month after discovering them. As part of a plea agreement, Unicat agreed to pay more than $3.3 million to DOJ, $3.8 million to OFAC, and $391,183 to BIS. OFAC agreed to credit about $3.3 million of its penalty against the fine Unicat owed to DOJ, and BIS agreed to credit its entire penalty against the fine owed to OFAC.
As part of the BIS settlement, Unicat admitted that its “predecessor entity" committed the violations. BIS said that included illegally selling and arranging the export of items subject to the Export Administration Regulations, including catalysts designated as EAR99. Those catalysts were valued at $391,182.78.
Unicat also will be subject to a three-year BIS probationary period. If the company commits another export violation during that time, BIS may revoke the company’s export privileges for three years. Unicat also must give BIS copies of the annual compliance certifications and reports that it’s required to give to OFAC and DOJ as part of its deals with those agencies.