“For the following reasons, I conclude that Nordic Maritime Pte. Ltd.’s (Nordic) and Morten Innhaug’s (Innhaug and, collectively, Respondents) conduct– including the knowing export of highly controlled equipment to one of America’s adversaries, coupled with making false and misleading statements to the Bureau of Industry and Security (BIS) in the course of its investigation into the matter–warrants a significant sanction. As a result, I affirm the $31,425,760 civil monetary penalty in its entirety and determine that no suspension of the penalty is appropriate.”

85 FR 52312-20
Published 08-25-2020