“This matter is before me to review the Administrative Law Judge’s (ALJ) February 7, 2020 Recommended Decision and Order (RDO). For the reasons discussed below, and upon review of the administrative record, I find there is sufficient evidence that Nordic Maritime Pte. Ltd. (Nordic) and Morten Innhaug (Innhaug and, collectively, Respondents) violated the Export Administration Regulations (EAR), that Nordic did so knowingly, and that Nordic made false statements to the Bureau of Industry and Security (BIS) in the course of its investigation. I further find that the evidence supports the conclusion that Innhaug caused, aided, or abetted Nordic’s unlawful reexport of the survey equipment in violation of EAR. The ALJ recommended a civil monetary penalty of $31,425,760, as well as a denial of export privileges until such time Respondents pay the civil monetary penalty. With respect to the RDO’s monetary penalty recommendation, I conclude the analysis of damages in the RDO is incomplete.”


85 FR 15414-28
Published 03-18-2020