Civil and Criminal Penalties

Violations of export control regulations are subject to criminal and civil penalties for both BUMC and individual.

Export Administration Regulations

Criminal Penalties:

Willful Violations

  • University: a fine of up to the greater of $1,000,000 or fives times the value of the export for each violation.
  • Individual: a fine of up to $250,000 or imprisonment for up to ten years, or both, for each violation.

Knowing Violations

  • University: a fine of up to the greater of $250,000 or five times the value of the export for each violation.
  • Individual: a fine of up to the greater of $250,000 or five times the value of the export or imprisonment for up to five years, or both, for each violation.

Civil Penalties:

The imposition of a fine of up to $250,000 for each violation.

Additionally, for each violation of the EAR any or all of the following may be imposed:

  • Denial of export privileges
  • Exclusion from practice
  • Seizure/forfeiture of goods
  • Inability to obtain federal contracts

International Traffic in Arms Regulations

Criminal Penalties:

  • University: a fine of up to $1,000,000 for each violation.
  • Individual: a fine of up to $1,000,000 or up to ten years in prison or both for each violation.

Civil Sanctions:

  • University: a fine of up to $500,000 for each violation.
  • Individual: a fine of up to $500,000 for each violation.

Additionally, for any violation of the ITAR either or both of the following may be imposed:

  • Denial of export privileges
  • Seizure/forfeiture of goods
  • Inability to obtain federal contracts

Office of Foreign Assets Control Regulations

Criminal Penalties:

  • University: a fine of up to $1,000,000 for each violation.
  • Individual: a fine of up to $1,000,000 or up to twenty years in prison, or both, for each violation.

Civil Penalties:

  • University: a fine of up to $250,000 for each violation.
  • Individual: a fine of up to $250,000 for each violation.

Additionally, for any violation of the OFAC regulations, seizure and forfeiture of goods may result.