|St. Jude Medical
Export GmbH Settles Charges of Antiboycott Violations
|October 4, 2004
| As posted by the Office of Antiboycott Compliance
US Department of Commerce
St. Jude Medical Export GmbH Settles
Charges of Antiboycott Violations
The U.S. Department of Commerce
today announced that St. Jude Medical Export GmbH (St. Jude), an Austrian
subsidiary of a Minnesota-based U.S. exporter of medical equipment, has agreed
to pay a $30,000 civil penalty to settle charges that it violated the
antiboycott provisions of the Export Administration Regulations (EAR).
The Commerce Departments Bureau of Industry and Security (BIS)
charged that St. Jude violated the EAR when it failed to report in a timely
manner its receipt of three requests from an Iraqi government agency to adhere
to the rules of the Israeli boycott during the 2000-2001 reporting period. BIS
also charged that, on four occasions, St. Jude violated the antiboycott
provisions by agreeing to refuse to do business with blacklisted persons.
The antiboycott provisions of the EAR prohibit U.S. persons from
complying with certain requirements of unsanctioned foreign boycotts, including
providing information about business relationships with another person who is
known or believed to be restricted from having a business relationship with or
in a boycotting country. In addition, the EAR requires that U.S. persons report
their receipt of certain boycott requests to the Department of Commerce. Under
the antiboycott provisions of the EAR, a controlled-in-fact foreign subsidiary
of a domestic U.S. company is considered a U.S. person.
voluntarily disclosed the transactions and cooperated fully with the
Assistant Secretary for Export Enforcement Julie L.
Myers commended Compliance Officer Perry Province of BISs Office of
Antiboycott Compliance, for his work on this case.