Air Shunt Instruments, Inc. has entered into a consent agreement with the DDTC to settle charges relating to unauthorized exports of defense articles and technical data and misrepresentations and omissions of material facts on an export control document. Based in California, Air Shunt supplies replacement parts and components for military aircraft to the Department of Defense and aerospace industry. According to the DDTC charging document, between September 2003 and January 2004, the company was involved in three separate sales of defense articles to Dubai and Thailand, each without a proper DDTC license. In addition, the company indicated in shipping documents that no license was required for the subject merchandise.
Under a July 2009 Consent Agreement, Air Shunt agreed to pay a US$100,000 civil penalty and implement remedial measures to strengthen its internal export control compliance procedures. The parties agreed that the US$100,000 fine could be applied against costs of improving its compliance program; US$70,000 for pre-consent agreement remedial compliance measures; and US$30,000 for consent agreement-authorized remedial compliance measures. In addition, Air Shunt has agreed to be subject to on-site reviews by the DDTC and 12- and 24-month audits by an outside consultant with export control experience.