Archive for the ‘Singapore’ Category

Illegal Exporting of IED Components Lands Singapore Native in Prison


By: Ashleigh Foor

Illegal exporting of goods lands Singapore native, Lim Yong Nam (aka Steven Lim), 43, in a lot of trouble. Forty months in prison kind of trouble to be exact. On December 15, 2016 Lim plead guilty to charges of conspiracy to defraud the US.

The conspiracy involved Lim’s and others’ involvement in the shipment of thousands of radio frequency modules from a Minnesota-based company to Iran.  The frequency transmitting technology used in these modules is related to that which connects office computers and printers wirelessly. The same technology is also used for remote detonation systems. Connected with the right antenna, the wireless capabilities can stretch 40 miles. But this technology was not shipped with the intention of setting up networks in an office building. Of the 6,000 modules shipped from Minnesota to Iran, 14 were later found in Iraq in unexploded improvised explosive devices (IEDs). According to case files, IEDs were the main source of American casualties in Iraq from 2001-2007.

Charges were first filed against Lim in June 2010, when he plead guilty to falsifying documents and breaking US law in order for 6,000 modules to ship from Minnesota to Singapore and finally to Iran through 5 shipments.  Lim admitted that he and his co-conspirators were aware of US restrictions on shipments to Iran and made false statements to indicate Singapore as the final destination.

After reaching Singapore, these shipments were combined with other electronic devices and stored with a freight forwarding company before being re-exported to Iran. There is no evidence of Lim having any physical contact with the modules.

From 2008 to 2009 several of these modules originating from Minnesota were found in Iraq being used for the remote detonation system for IEDs. With US request for extradition, Indonesia detained Lim in 2014. After being extradited to the US in 2016, Lim plead guilty to charges of conspiracy against the US and will be deported after his sentence.

Interestingly, the Minnesota supplier has not been charged for any violations related to the exports in question.

Middle Man in Illegal Exports Debarred for 8 Years


By: Danielle McClellan

Walter Anders and his company Terand, Inc. (he was the sole employee) of Huntersville, NC has been debarred for 8 years for his connection in exporting carbon fiber to Singapore. Anders and his company were used as a middle man to send illegal exports from a company in Middlewtown, NY to a company in Singapore in exchange for multiple $1,400 kick backs.

In 2012, Performance Engineered Nonwovens, of Middletown, NY, was contacted by BIS and told that their license to export T300 carbon fiber (ECCN 1C210.a) to Singapore was revoked due to the concerns surrounding the recipient. Performance Engineered Nonwovens then sought out to find a way to conceal the shipments to Singapore, cue Walter Anders and Terand.  Within a few weeks Anders and the president of Performance Engineered Nonwovens, Peter Gromacki, agreed to have Terand falsely act as the US exporter of record for exports of the items to Singapore in return for a $1,400 commission for each successful export.

Terand created and issued commercial invoices on letterhead that falsely named Terand as the exporter and falsely stated that, “This commodity technology exported from the United States is in accordance with the Export administration Regulations.” The company also acted as the intermediary between Performance Engineered Nonwovens and the freight forwarder, providing instructions to the forwarder, signing any and all required shipping documents, and receiving status reports on the progress of exports to Singapore. Terand also appeared as the US Principal Party in Interest (USPPI) on all of the Shipper’s Export Declarations (SED) that were filed.

Over the course of 2012 Terand made 8 exports of T300 carbon fiber to Singapore (approximately 6,557kg). Gromacki (Performance Engineered Nonwovens president) ensured that this process would continue and told Walter Anders that, “You continue to play a crucial role. I cannot export without your help and hence the commission checks will continue to flow in your direction.”

Walter Anders and his company, Terand, have been charged with 8 counts of Causing, Aiding, and/or Abetting Unlicensed Exports. The 8 illegal exports were valued at $288,736, Anders received $11,200 in commissions and 8 years of debarment.

Federal Register:

Singaporean Extradited for Illegal Exports Later Found in IEDs


By: Danielle McClellan

Lim Yong Nam (known as Steven Lim), a citizen of Singapore, has been extradited from Indonesia to stand trial in Washington, DC on charges of conspiracy.  He allegedly caused 6,000 radio frequency modules to be illegally exported from the US to Iran. Over the course of May 2008 and July 2010, sixteen of the modules were found in unexploded IEDs recovered in Iraq by coalition forces.

Between 2007 and February 2008 Lim and others in Singapore purchased 5 shipments of radio frequency modules from a Minnesota-based company by falsifying documents that stated the modules would stay in Singapore. When the modules were purchased they were always destined for Iran, however, Lim and his Singapore counterparts knew this would not be approved by the US government so they concealed the ultimate origin from the US manufacturer.

In 2009, when Lim was questioned by US authorities he was adamant that he never participated in any illicit exports to Iran. Communications were later found between Lim and several others regarding the US export rules and the issues with sending the modules to Iran.

Lim is currently facing the following charges:

  • One count of conspiracy to defraud the US
  • One count of smuggling
  • One count of Illegal export of goods from the US to Iran
  • One count of making false statements to the US Government
  • One count of making false statements to law enforcement

More details:

Export Coordinator Gets Prison Time for EAR Violations


By: Brooke Driver

“Play nice” may have been a lesson you learned in preschool, but the rule still applies—as shown recently in the case of Amplified Research Corporation. The Pennsylvania company’s former export coordinator Timothy Gormley was sentenced to 42 months in prison and 10 years debarment this January for his illegal shipments of U.S.-controlled amplifiers to Hong Kong, the People’s Republic of China, Taiwan, Singapore, Thailand, Korea and Malaysia. Apparently, the total value of the amplifiers, which are controlled due to their potential military applications as radar jammers and weapons guidance systems, was nearly $3,000,000. Twenty-five of the fifty illegal exports were to the People’s Republic of China.

Gormley certainly paid the price for his crimes, but what about his company? Amplified Research itself seems to have gotten off nearly scot free, which is rather surprising considering the high number of violations and the value of the products involved in the case. Eric L. Hirschhorn, Undersecretary of Commerce for Industry and Security, took note of Amplified Research’s cooperation with BIS throughout its investigation, including the company’s submission of a voluntary self-disclosure describing Gormley’s action. As a result, BIS has decided to waive the $500,000 fine, assuming Amplified Research does not violate the regulations in the next two years, and only requires that the company perform an outside audit. Lesson learned? Cooperation will go a long way in lessening the consequences of a violation.

Singapore Businessman Pays the Price for Ignoring BIS Charges


By: Brooke Driver

Three years ago—February 10, 2010 to be exact—BIS issued an official charging letter accusing Chan Heep Loong, Singapore resident and owner of Tysonic Enterprises, of violating U.S. export regulations on three separate counts. Specifically, the Bureau of Industry and Security claimed that Loong violated the Iranian Transactions Regulations on two occasions, ordering U.S.-made products supposedly to be shipped to Singapore that were actually transshipped to Iran. In the first case, these unlicensed items were GPS engines, controlled under ECCN 7A994, and in the second, it was a peak power meter, controlled under ECCN 3A992. In this letter, BIS also accused Loong of violating a temporary denial of export issued in April of 2006. Unfortunately, for Loong, this denial is no longer temporary.

Although BIS had been in contact with a Singapore lawyer acting for Loong a number of times since the issuance of the charging letter, Loong himself did not respond to the charges in a timely manner (actually, at all), and so the Bureau, rather than demanding a fine, chose to revoke Loong’s and his company’s export privileges for the maximum period of ten years. It seems that in this case, BIS has chosen to make an example out of Loong, more due to his refusal to acknowledge the charges against him than the actual charges themselves, a BIS official citing “the importance of deterring…others from acting to evade the Regulations and otherwise knowingly violat[ing] the Regulations.”

For the Second Time in 2012 Singapore Extradites People to US to Face Illegal Export Charges


By: John Black

On December 212, 2012, 5he US Department of Justice announced that Hia Soo Gan Benson, aka “Benson Hia,” and Lim Kow Seng, aka “Eric Lim,” have been extradited from Singapore to stand trial in the Washington, DC in connection with an alleged fraud conspiracy involving the unlawful export of 55 military antennas from the United States to Singapore and Hong Kong.

This is the second high profile case this year in which Singapore decided to extradite people to the United States for violations of US export and reexport controls. In February 2012, a court in Singapore ruled that 4 people could be extradited for their involvement in a conspiracy to transfer commercial electronic components to Iran. For more information on that story go to: For more information on that story go to:

Hia and Seng, both citizens of Singapore, were arrested by Singaporean authorities on Oct. 24, 2011, in connection with a U.S. request for extradition. Hia and Seng each face one charge of conspiracy to defraud the United States by violating the Arms Export Control Act. If convicted, each defendant faces a potential sentence of five years in prison.

An indictment returned in Washington, DC on Sept. 15, 2010 alleges that Hia and Seng conspired to defraud the United States by causing a total of 55 cavity-backed spiral antennas and biconical antennas to be illegally exported from a Massachusetts company to Singapore and Hong Kong without the required State Department license. These military antennas are controlled for export as U.S. munitions and are used in airborne and shipboard environments.

Hia and Seng are alleged to have, among other things, conspired to undervalue the antennas to circumvent U.S. regulations on the filing of shipper’s export declarations to the U.S. government. They also allegedly used false names and front companies to obtain the antennas illegally from the United States.

US regulations apply to exports from the United States and reexports of US items outside of the United States from one country to another. US regulations also apply to certain non-US origin items with US content. The United States strictly and harshly enforces its regulations on companies outside of the United States as evidenced by the US Government $25 million settlement with Singapore company Qioptic for violations of US regulations in January 2009. Qioptic agreed to pay the penalties in that case even though nobody was extradited to the United States. For information on that case go to:

Singapore joins the United Kingdom, another country who has extradited its citizens to the United States to face charges related to illegal exports, in clearly demonstrating its willingness to cooperate with the US Government’s export control program for commercial and military products. This recent extradition reinforces that it is critically important for companies in Singapore and elsewhere to the importance of complying with US export and reexport controls.

10 Shipping Companies & 3 Individuals Affiliated with Iran’s National Shipping Line- Denied


By: Anna Barone

Continuing efforts to target the financial underpinnings of the Islamic Republic of Iran Shipping Lines (IRISL), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the designation of 10 shipping companies and three individuals affiliated with IRISL. Responding to Iran’s continued efforts to evade sanctions and its ongoing creation and use of new front companies, subsidiaries, and affiliates to protect IRISL and to advance its proliferation activities, today’s actions targeted IRISL’s operations in the United Arab Emirates (UAE), Singapore, China and the United Kingdom (UK).

Great Scott Batman, Another Illegal Valve Exporter!


By: John Black

You don’t have to have Batman’s “bat senses” to figure out that the pump and valve industry is doing their part to keep US Government export enforcement personnel busy.  This time, the culprit is Tyco Valves & Controls (TVC) with 26 violations for illegal exports of ECCN 2B350 butterfly valves, ball valves, and valve assemblies to China, the UAE, Mexico, India, Israel, Brazil, Singapore, Chile, Jordan and El Salvador. The violations occurred between January 2005 and March 2007.

In this case, the US Government did not have to bring in Batman to find these illegal exports.  TVC voluntarily disclosed its violations to the Department of Commerce and agreed to pay a $218,000 penalty to settle the charges.

“Buying Export Violations” or “When Will the Valve Companies Catch On?”


By: John Black

I don’t know if my first observation should focus on successor liability or the fact that this is another 2B350 violation.  So I will start with a few facts.

Wesco Industrial Products, Inc. of Lansdale, PA agreed to pay a $50,000 in a settlement agreement with the Bureau of Industry and Security resulting from its voluntary disclosure of some relatively harmless exports of ECCN 2B350 valves.  Wesco is the surviving entity of several mergers that occurred in 2008 and is the successor to Neptune Chemical Pump Co., Inc.  The violations all occurred before the merger.

The violations involved these exports of 2B350 relief valves:

  • An export of ten valves to Singapore
  • An export of two valves to Mexico
  • An export of four valves to Hong Kong

It is reasonable to assume the small $50,000 fine is due to the fact that the company did a voluntary disclosure, the violations were due to ignorance, and that the valves ended up in harmless locations.

The lessons are:

  1. If you acquire or merge with a company that is has past violations, the resulting entity now owns the violations.
  2. Companies who manufacture chemical processing such as valves and pumps still don’t seem to have caught on to the fact that their seemingly harmless products may require export licenses.  There has been a relatively steady stream of violations involving 2B350 valves and pumps.  It makes me feel like taking out an ad in some valve and pump trade journal to shout out:  Don’t let this happen to you.

$450,000 Penalty ($400,000 Suspended) for Illegal Valve and Pump Exports


By: Danielle McClellan

FSI International, Inc. was charged with 66 violations of the EAR after the company voluntarily self disclosed the violations to BIS earlier this year. The charging letter stated that between 2003 and 2006 FSI exported fluoropolymer-coated valves and pumps from the US to China, Israel, Malaysia, Taiwan, and Singapore. The valves and pumps are classified 2B350 for chemical and biological weapons proliferation reasons.

FSI was fined $450,000 in conjunction with the 66 violations, but don’t feel too sorry for them. The Order states that FSI will have to pay $50,000 over a period of 9 months ($5,000 per month) and the remaining $400,000 will be suspended as long as FSI doesn’t commit any violations in the next year.