On 17 September 2014, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that an Italian company, Area S.p.A., agreed to a $100,000 civil penalty to settle allegations that the company knowingly violated US export controls by selling US-origin telecommunications equipment to the Syrian Telecommunications Establishment (“STE”) without required authorisation from the US government. According to BIS, the violation arose from a sale  of a Central Monitoring System (“CMS”) capable of collecting data about web surfing, emails, online chatting and VOIP calling to STE. The sale of the CMS to STE was not subject to US export controls because the CMS contained only de minimis US content. However, Area subsequently transferred US-origin networking equipment to STE to monitor and test the CMS without the necessary US government authorisation for this transfer. BIS alleges that Area knew at the time of the transfer that US export regulations prohibited the unlicensed transfer of the equipment to Syria and that, in the hands of the Syrian government, the system “could be used to further the repression of the Syrian people.”

US Department of Commerce Press Release