Respondent: Smith International (North Sea) Limited, Crawley, United Kingdom
Charges: 15 CFR 764.2(a), on nine occasions between on or about April 6, 2008 and on or about January 27, 2010, Smith International (North Sea) Limited (SNIS) engaged in conduct prohibited by the Regulations when it reexported items subject to the Regulations from the United Arab Emirates to Syria without the required Department of Commerce authorization. Specifically, SINS reexported to Syria drilling tools and equipment, items subject to the Regulations and designated EAR99, and valued at approximately $174,000. The reexport of these items required a license from the Department of Commerce pursuant to General Order No. 2, set forth in Supplement No.1 to Part 736 of the Regulations, which implements the Syria Accountability and Lebanese Sovereignty Act of 2003 (Pub. L. No.1 08-175). In reexporting these items to Syria without a license, Smith International committed nine violations of Section 764.2(a) of the Regulations.
Fine or Civil Settlement: Civil Settlement of $130,000
Debarred or Suspended from Export Transactions: Not if penalty is paid by Smith International as agreed.
Result of Voluntary Self-Disclosure: No
Date of Order: 23 December 2013