Order Relating to Ali Eslamian, Equipco (U.K.) Ltd., and Skyco (U.K.) Ltd.

September 28, 2017

The Bureau of Industry and Security, U.S. Department of Commerce ("BIS"), has notified Ali Eslamian, of London, United Kingdom ("Eslamian"), that it has initiated an administrative proceeding against Eslamian pursuant to Section 766.3 of the Export Administration Regulations (the "Regulations"), and Section 13(c) of the Export Administration Act of 1979, as amended (the "Act"), through the issuance of a Charging Letter to Eslamian that alleges that Eslamian committed one violation of the Regulations.

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WHEREAS, BIS and Eslamian, Equipco (UK) Ltd., and Skyco (UK) Ltd. (the "Parties") have entered into a Settlement Agreement pursuant to Section 766.18(b) of the Regulations, whereby they agreed to settle this matter in accordance with the terms and conditions set forth therein;

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WHEREAS, I have approved of the terms of such Settlement Agreement; 
IT IS THEREFORE ORDERED:

FIRST, Eslamian shall be assessed a civil penalty in the amount of $250,000. The payment of $100,000 shall be made to the U.S. Department of Commerce in four installments of: $25,000 no later than November 1, 2017; $25,000 no later than February 1, 2018; $25,000 no later than May 1, 2018; and $25,000 no later than August 1, 2018. Payment of the remaining $150,000 shall be suspended for a period of four years from the date of this Order, and thereafter shall be waived, provided that during this fouryear payment probationary period: Eslamian has timely paid $100,000 to the Department of Commerce as set forth above; has otherwise complied with the provisions of the Settlement Agreement and this Order; and has committed no other violation of the Act or the Regulations or any order, license or authorization issued thereunder.

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EIGHTH, as authorized by Section 766.18(c) of the Regulations, the four-year denial period set forth above shall be suspended during a probationary period of four years under this Order, and shall thereafter be waived, provided that Eslamian has made full and timely payment as set forth above, has otherwise complied with the provisions of the settlement agreement and this Order, and provided that the Denied Persons (as defined in Paragraph FIFTH above) have committed no other violation of the Act or the Regulations or any order, license or authorization issued thereunder. If Eslamian does not make full and timely payment as set forth above, violates the cooperation provision in Paragraph NINTH of this Order, or any of the Denied Persons commits another violation of the Act or the Regulations or any order, license or authorization issued thereunder, during the four-year probationary period under this Order, the suspension may be modified or revoked by BIS and a denial order including a four-year denial period activated against the Denied Persons. If a denial order is activated, any license issued pursuant to the Act or the Regulations in which any of the Denied Persons has an interest at that time shall be revoked. 

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