“On August 12, 2015, in the U.S. District Court for the District of Maryland, Sam Rafic Ghanem (‘Ghanem’), was convicted of violating section 38 of the Arms Export Control Act (22 U.S.C. 2778 (2012)) (‘AECA’). Specifically, Ghanem willfully attempted to export and cause the exportation of firearms parts and accessories designated as defense articles under Category I of the United States Munitions List from the United States to Lebanon without having first obtained the required license or authorization from the U.S. Department of State, Directorate of Defense Trade Controls. Ghanem was sentenced 18 months in prison, three years of supervised release, a criminal fine of $70,734.24, and a $200 assessment. Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, I have decided to deny Ghanem’s export privileges under the Regulations for a period of 10 years from the date of Ghanem’s conviction. I have also decided to revoke all licenses issued pursuant to the Act or Regulations in which Ghanem had an interest at the time of his conviction.”

82 FR 17187-88
Published 04-10-2017