Understanding the Office of Export Enforcement and Its Role

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The Office of Export Enforcement (OEE) is a key player in ensuring that the United States' export laws are enforced. Established in 1996, the OEE is responsible for investigating and prosecuting offenses related to the export of defense articles and defense services.

The OEE's main goal is to prevent the unauthorized export of sensitive technologies that could harm national security. This includes investigating cases of prohibited exports to countries like China, Russia, and Iran.

The OEE works closely with other agencies, such as the Department of Commerce's Bureau of Industry and Security (BIS), to ensure that exports comply with regulations. This collaboration helps to identify and prevent potential export control violations.

What is Export Enforcement?

Export Enforcement is a critical component of the Office of Export Enforcement, tasked with protecting and promoting U.S. national security by aggressively investigating violations of export control and antiboycott regulations.

Its primary goal is to ensure compliance with those regulations, which is achieved through partnerships with industry and academia.

Export Enforcement works closely with these stakeholders to facilitate compliance and prevent unauthorized exports that could compromise national security.

By doing so, it helps to safeguard the country's strategic interests and prevent the potential misuse of sensitive technologies.

Investigations and Cases

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The Office of Export Enforcement (OEE) takes a proactive approach to investigating export control violations. They review export documentation and conduct overseas end-use verifications to identify potential issues.

OEE Special Agents initiate investigations based on information from various sources, including industry and supply chain sources. They work closely with other federal agencies to identify and act on export violations.

OEE investigates unauthorized re-exports or transfers by foreign persons of items subject to the Export Administration Regulations (EAR) to prohibited end-uses, end-users, or destinations. They also investigate U.S. persons who violate export control laws.

Investigation Scope

The Office of Export Enforcement (OEE) investigates a wide range of export control and public safety statutes, including the Export Control Reform Act and the International Emergency Economic Powers Act.

These investigations can be initiated through various means, such as routine review of export documentation or overseas end-use verifications.

OEE Special Agents work closely with other federal law enforcement agencies, like the U.S. Immigration and Customs Enforcement's Homeland Security Investigations (HSI), to identify and act on export violations.

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The OEE focuses on investigating U.S. persons who have committed export violations, as well as foreign persons who have unauthorized re-exported or transferred items subject to the Export Administration Regulations (EAR) to prohibited end-uses, end-users, or destinations.

OEE works with industry to raise awareness of compliance best practices and "red flag" indicators of potential illicit activities, helping to prevent export violations from occurring in the first place.

In addition to investigating export violations, OEE also investigates unauthorized re-exports or transfers of items subject to the EAR, regardless of location.

Significant Cases Investigated

The FBI investigated the 1963 assassination of President John F. Kennedy, a case that remains one of the most infamous in American history.

One of the most notable aspects of this case was the Warren Commission's conclusion that Lee Harvey Oswald acted alone.

The 1972 Watergate scandal involved the break-in at the Democratic National Committee headquarters, which led to a wide-ranging investigation that implicated President Richard Nixon's administration.

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Investigations into the scandal ultimately led to the resignation of President Nixon in August 1974.

The FBI's investigation into the 1993 World Trade Center bombing led to the conviction of several defendants, including Ramzi Yousef and Mahmud Abouhalima.

The Oklahoma City bombing in 1995 was investigated by the FBI, who identified Timothy McVeigh and Terry Nichols as the primary suspects.

The 9/11 attacks in 2001 led to a massive investigation by the FBI and other agencies, resulting in the identification of several key conspirators.

The Boston Marathon bombing in 2013 was investigated by the FBI, who identified Dzhokhar and Tamerlan Tsarnaev as the primary suspects.

Mayrow Trading Network

Mayrow Trading Network was a distributor and reseller of electronic components located in Dubai, UAE. They utilized a network of organizations and individuals to redirect US origin goods and technology to end-users in Iran.

The company was found to have sold components to Mayrow from a US exporter that ended up in an unexploded roadside bomb in Iraq in 2005. At the time, the exporting company wasn't required to apply for a license because the goods were below export control thresholds.

BIS responded by issuing General Order No. 3 in Part 736 of the Export Administration Regulations, which imposed a license requirement for goods and technology exported or re-exported to the individuals and companies in the Mayrow General Trading Network.

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Notable Cases

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The Office of Export Enforcement has been involved in some notable cases over the years. One notable case was the prosecution of a California businessman who was sentenced to prison for conspiring to export U.S.-made missile technology to China.

The case involved the export of sensitive technology without the required licenses. The businessman was caught after a lengthy investigation by the Office of Export Enforcement.

The Office of Export Enforcement has also been involved in cases involving the export of defense articles to countries subject to U.S. arms embargoes. In one case, a Florida-based company was fined for exporting defense articles to Cuba.

The company had attempted to disguise the true nature of the exports by misrepresenting the end-user and the destination of the shipments. The Office of Export Enforcement was able to uncover the scheme through its investigation.

The Office of Export Enforcement has also worked with other agencies to enforce export controls. In one case, the agency collaborated with the U.S. Customs Service to intercept a shipment of restricted technology being exported to Iran.

The shipment was seized and the exporter was fined for violating U.S. export laws.

Programs and Initiatives

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The Office of Export Enforcement has several programs and initiatives in place to prevent illegal exports and protect national security and foreign policy objectives. One such program is the Outreach Program, which educates industry about export controls and elicits cooperation.

The Outreach Program involves one-on-one visits with company representatives, typically in person but sometimes over the phone. Manufacturers, exporters, and freight forwarders are among the types of companies contacted.

Sentinel Program

The Sentinel Program is a key initiative that conducts end-use checks through BIS' Sentinel Program. Trained OEE Special Agents are deployed from the United States to visit the end-users of sensitive controlled commodities.

These agents assess whether these items are being used in accordance with license conditions. Sentinel teams also assess the suitability of foreign end-users to receive U.S.-origin licensed goods and technology.

Prospective end-users on pending license applications are evaluated for diversion risk. This helps to create the confidence needed to foster trade while strengthening U.S. national security.

Sentinel teams conduct educational outreach to foreign trade groups. This outreach helps to promote compliance with U.S. regulations and strengthen international cooperation.

Outreach Program

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The Outreach Program is designed to educate industry about export controls and prevent illegal exports by eliciting industry's cooperation in protecting national security and foreign policy objectives.

This program involves one-on-one visits with company representatives, known as Outreach contacts, which are typically conducted in person but can also be done over the phone in certain instances.

The types of companies contacted through the Outreach Program include manufacturers, exporters, and freight forwarders.

Frequently Asked Questions

What is a red flag for an export transaction?

A red flag for an export transaction is when the recipient is secretive about the material's end-use or the product doesn't align with their business or expertise

When should you contact the export control office?

Contact the export control office if you're unsure about sharing research results or transferring controlled commodities or software abroad. This includes situations where you're not sure if your work falls under export control regulations.

Clara Donnelly

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Clara Donnelly is a versatile writer with a passion for crafting engaging content across various industries. With a keen eye for detail and a knack for storytelling, she brings complex topics to life through her writing. Her expertise spans a range of topics, including sustainable packaging solutions, where she explores innovative ideas and eco-friendly practices that minimize waste and promote environmental responsibility.

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