UAE company agrees to $2.8 million penalty to settle EAR violations for internet monitoring devices transferred to Syria 

April 25:   The Commerce Department’s Bureau of Industry and Security (BIS) today announced that a Dubai company has agreed to pay a $2.8 million civil penalty to settle allegations that it committed three violations of the Export Administration Regulations (EAR) related to the transfer to Syria of devices designed to monitor and control internet traffic.

In addition to the civil penalty, which is the statutory maximum, the UAE company agreed to submit to independent, third-party audits.


BIS alleged that on three occasions in 2010 and 2011, the company engaged in transactions or took actions with the intent to evade the EAR in connection with the unlawful export and re-export to Syria of equipment and software obtained from a California company and designed for use in monitoring and controlling internet traffic. The equipment and software are “controlled” due to national security and anti-terrorism reason, and as encryption items, and valued at approximately $1.4 million.

BIS reported that:

  • The UAE company was an authorized distributor in the Middle East for the California company, and for distributing hardware and software products and providing support services to resellers and end-users, including account, sales, and installation support and assistance.
  • The UAE company the U.S. manufacturer and exporter with false information concerning the end-user and ultimate destination of the items in connection with these transactions.
  • The UAE company knew that the items were destined for end-users in Syria, but in placing these orders, falsely stated that the ultimate destination and end-users for the items was the Iraq Ministry of Telecom (on two occasions) or the Afghan internet service provider.
  • The items subsequently were shipped to the UAE company for ultimate delivery to Syria without the required licenses having been obtained.

Read the BIS release.

For more information, contact a professional with KPMG’s Trade & Customs practice:

Douglas Zuvich

(312) 665-1022

Andrew Siciliano

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John L. McLoughlin

(267) 256-2614

Todd R. Smith

(949) 885-5617

Luis A. Abad

(212) 954-3094

Amie Ahanchian

(202) 533-3247

Or your local KPMG Trade & Customs professional.

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