“On October 2, 2015, the Bureau of Industry and Security (‘BIS’) issued a Charging Letter to Respondent Trilogy International Associates, Inc. (‘Trilogy International’ or ‘Trilogy’), alleging that Trilogy committed three violations of Section 764.2(a) of the Export Administration Regulations (‘EAR’ or ‘Regulations’), by exporting national-security-controlled items to Russia without the required BIS licenses. On the same date, BIS also issued a Charging Letter to William Michael Johnson (‘Johnson’), Trilogy’s President and General Manager, alleging that Johnson committed three violations of Section 764.2(b) of the Regulations by causing, aiding, and/or abetting Trilogy’s unlawful exports.”
83 FR 9259-67
Published 03-05-2018
