BIS: Renewal of Temporary Denial Order for Flider & Trident
From Federal Register, Volume 80 Issue 181 – September 2015:
Renewal of Order Temporarily Denying Export Privileges: Flider & Trident (and d/b/a ‘s)
Pursuant to Section 766.24 of the Export Administration Regulations, I hereby grant the request of the Office of Export Enforcement (“OEE”) to renew the March 23, 2015 Amended Order Temporarily Denying the Export Privileges of Flider & Trident (and d/b/a ‘s).
I find that renewal of the Temporary Denial Order (“TDO”) is necessary in the public interest to prevent imminent violation of the EAR.
Despite the issuance of the TDO and the execution of the search warrants, Trident repeatedly sought to order or buy items subject to
the EAR from a U.S.-based electronics distributor from whom Trident had previously purchased items for export. Beginning on or about July 10, 2015, through on or about July 21, 2015, while the TDO by its plain terms remained in effect, Pavel Flider contacted employees of this electronics distributor requesting to reestablish Trident’s account and make additional purchases of electronic components, including for computer chips. Several of the distributor’s employees were solicited in an effort to place additional purchase orders for more computer
chips for Trident. The computer chips, which OEE has reason to believe were intended for export based upon the respondents’ conduct both prior to and after issuance of the TDO,\3\ are subject to the EAR.
The Findings:
I find that the overall record here, as discussed above and in the TDO as issued and amended in March 2015, demonstrates that renewal of
the TDO is necessary to avoid imminent violation of the EAR, based upon the evidence presented by OEE of deliberate and evasive conduct both pre- and post-issuance of the TDO. Accordingly, renewal of the TDO is needed to provide continued notice to persons in the United States and abroad that they should not deal with respondent Trident, or with related and denied persons Pavel Flider and Gennadiy Flider, in connection with any exports, reexports, or other transactions involving any items subject to the EAR or any other activities subject to the EAR. Doing so is consistent with the public interest to preclude future violations of the EAR.
-> This Order is effective upon issuance and shall remain in effect for 180 days.
To read all details of the order.
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