BIS Issues Export Denial Order for Illegal Exports to Russian Entries on Entity List
The Bureau of Industry and Security denied a New Jersey man export privileges after he illegally exported electronic components to Russia, BIS said in a March 8 order. BIS denied Alexander Brazhnikov export privileges for 15 years. Brazhnikov pleaded guilty to the charges in 2015 and was sentenced to 70 months in prison in 2016 (see 1607010044).
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BIS said Brazhnikov worked to export controlled electronics to Russian end-users, including defense contractors and suppliers for Russia’s military and the Federal Security Service. He also exported goods to Russian entities on BIS’ Entity List, including about $45,000 worth of goods to the All-Russian Scientific Research Institute of the Technical Physics. Brazhnikov tried to hide the shipments from authorities, including through falsified shipping documents and by “re-packaging and re-labeling” the goods and shipping them to “false” addresses in Russia. Brazhnikov and others also opened various foreign bank accounts under front companies to hide the source of the payments from the U.S. government
An administrative law judge approved BIS’s decision to impose a 15-year export denial order despite Brazhnikov arguing for a six-month denial order. The agency said the judge “noted the years-long scheme, the sophisticated effort to evade detection, the deliberateness of the violation, and that the end-user for the transactions described in the Charging Letter was an organization on BIS’s Entity List.” BIS said the judge’s “analysis in support of the recommended sanction was well-reasoned and persuasive.”