“actions with the intent to evade the Regulations in connection with the unlawful export and reexport to Syria of items subject to the Regultions. The items included equiptment and software designed for use in monitoring and controlling Web traffic that are classified under Export Control Classification Numbers (ECCNs) 5A002 and 5D002 … controlled for National Security and Anti-Terrorism reasons and as Encryption items, and valued at approximately $1,400,000.”

It appears that Computerlinks personnel lied not only to to its California-based supplier, Blue Coat Systems in Sunnyvale, California, but to BIS investigators as well. On its website, Computerlinks says it has more than twenty-five years of experience in IT technology and information security. It seems that its internal compliance program needs to catch up to their technological know-how. BIS is seeing to that.

According to the Order, Computerlinks will need to perform three external audits of its export compliance program to review and, as necessary, implement a compliance program to ensure that senstitive U.S. technology does not end up in the wrong hands. They will be busy on the compliance front for at least two years. Likely more.

You can read the BIS Order here.