Civil and Criminal Penalties

Violations of export control regulations are subject to criminal and civil penalties for Boston University and the individual employee, student, or faculty member.

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 10 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 10 years in prison, or both, for each violation.

Civil Penalties:

  • 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 20 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.