According to a post on Exportlawblog.com, the Carlsbad-based life sciences company Invitrogen has agreed to a settlement of $30,000 with the Bureau of Industry and Security for “three shipments and one attempted shipment of human leukocyte antigen tissue typing trays to Syria without a license.”
The shipments and attempted shipments had been made, and voluntarily disclosed, by Dynal Biotech, which Invitrogen acquired in 2005. The charging documents allege that these shipments and alleged shipments violate General Order No. 2 of Part 736 of the Export Administration Regulations which forbids exports of all items “except food and medicine” to Syria.
Exportlawblog.com goes on to say that by the letter of the law Dynal Biotech did nothing wrong, as tissue typing trays are clearly medical equipment that is included in the export exclusions. It was, however, cheaper to settle than to fight. . . and apparently much smarter from a business perspective.
[Link: Exportlawblog.com]