US BIS Export Privileges Denial Orders

Updated on: Dec 7, 2021

Latest Event


  • Dec. 2021 Douglas Glover Added to Denial List
  • On Dec. 6, 2021, BIS published Federal Register denial of export privileges for Douglas Glover, for knowingly attempting to export AK-47 magazines, without a license.
  • Violated 18 U.S.C. 554(a), restricted from directly or indirectly participating in any transactions involving any commodity, software or technology, exported from the US.
  • Prohibited from having affiliate participate in transactions involving commodity, software or technology, being exported from US on his behalf, or benefiting from trade.
  • Prohibited from applying for, obtaining, or using any license, license exception, or export control document, or being involved in negotiations on items exported from US
  • Order denying export privileges is effective immediately, in effect until Apr. 8, 2026.

On Sep. 14, US BIS published several export privilege denial orders.

  • US BIS published denial orders against several individuals for illegal exports to various countries in violating Section 38 of Arms Export Control Act (22 USC 2778) (AECA).
  • Defense articles are on United States Munitions List, and without having first obtained the required licenses or written approval from the United States Department of State.
  • Background
  • Section 1760(e) of Export Control Reform Act of 2018 (ECRA) allows denial of export privileges of persons convicted of certain offenses, including, section 38 of AECA.
  • Privileges may be denied for up to ten (10) years from the date of his/her conviction.
  • In addition, any US BIS licenses or other authorizations issued under ECRA, in which the person had an interest at the time of the conviction, may be revoked.
  • Additions to Denial List
  • Tengiz Sydykov who was convicted for knowingly and willfully exporting and causing to be exported from the United States to Grozny, Chechnya, Russia defense articles.
  • Andy Lloyd Huebschmann also convicted of violating AECA with exports to Australia.
  • Rrok Martin Camaj to Australia; Eli Ramirez-Rios to MEX; Katherine O'Neal to DR.
  • Dec. 2021 Marco Sanchez Added to Denial List
  • On Dec. 6, 2021, Federal Register published denial of export privileges for Marco Sanchez, knowingly, attempting to export firearm and ammunitions from the US.
  • Violated 18 U.S.C. 554(a), restricted from directly or indirectly participating in any transactions involving any commodity, software or technology, exported from the US.
  • Sentenced to 204 days in prison, two years supervised release, $100 assessment.
  • Prohibited from having affiliate participate in transactions involving commodity, software or technology, being exported from US on his behalf, or benefiting from trade.
  • Prohibited from applying for, obtaining, or using any license, license exception, or export control document, or being involved in negotiations on items exported from US.
  • Order denying export privileges is effective immediately, in effect until Jun. 16, 2025.
  • Dec. 2021 Ali Kourani Added to Denial List
  • On Dec. 6, 2021, Federal Register published denial of export privileges for Ali Kourani for conspiring to receive military training from Hizballah, providing financial support.
  • Kourani was also convicted of conspiring to receive funds, goods and services from Hizballah, in violation of 18 U.S.C. 371 AND 50 U.S.C. 1701, among other crimes.
  • Prohibited from having affiliate participate in transactions involving commodity, software or technology, being exported from US on his behalf, or benefiting from trade.
  • Prohibited from applying for, obtaining, or using any license, license exception, or export control document, or being involved in negotiations on items exported from US.
  • Sentenced to 480 months in prison, five years supervised release, $700 assessment.
  • Order denying export privileges is effective immediately, in effect until Dec. 3, 2029.
  • Dec. 2021 Douglas Glover Added to Denial List
  • On Dec. 6, 2021, BIS published Federal Register denial of export privileges for Douglas Glover, for knowingly attempting to export AK-47 magazines, without a license.
  • Violated 18 U.S.C. 554(a), restricted from directly or indirectly participating in any transactions involving any commodity, software or technology, exported from the US.
  • Prohibited from having affiliate participate in transactions involving commodity, software or technology, being exported from US on his behalf, or benefiting from trade.
  • Prohibited from applying for, obtaining, or using any license, license exception, or export control document, or being involved in negotiations on items exported from US
  • Order denying export privileges is effective immediately, in effect until Apr. 8, 2026.
Regulators
US BIS
Entity Types
Bank; Corp
Reference
86 FR 69008, 12/6/2021; 86 FR 69007, 12/6/2021; 86 FR 69006, 12/6/2021; 86 FR 51113, 9/14/2021; 86 FR 51117, 9/14/2021; 86 FR 51116, 9/14/2021; 86 FR 51115, 9/14/2021; 86 FR 51114, 9/14/2021; Citation: Section 1760(e) of Export Control Reform Act; Section 38 of Arms Export Control Act; 18 U.S.C. 554(a); 18 U.S.C. 371; 50 U.S.C. 1701;
Functions
AML; Compliance; Legal; Operations; Sanctions
Countries
United States of America; Cross-Border
Category
State
N/A
Products
Banking; Corporate
Rule Type
Final
Regions
Am
Rule Date
Sep 14, 2021
Effective Date
Jun 16, 2025
Rule ID
116042
Linked to
N/A
Reg. Last Update
Dec 6, 2021
Report Section
AML & Enforcement