“This matter is before me upon a Recommended Decision and Order on Sanction (‘Sanction RDO’) of an Administrative Law Judge (‘ALJ’). On January 26, 2021, the ALJ referred the Sanction RDO to me pursuant to 15 CFR 766.17(b)(2). In the Sanction RDO, the ALJ found that Respondent Alexander Brazhnikov, Jr. (‘Respondent’) violated 15 CFR 764.2(d) by conspiring with others to violate the Export Administration Regulations (currently codified at 15 CFR parts 730-774) (‘EAR’ or ‘Regulations’) by exporting regulated items to Russian EndUsers on the Entity List without the required licenses. The ALJ recommended that a denial of export privileges for 15 years be assessed against Respondent. For the reasons set forth below, I affirm the Sanction RDO and issue the attached Order imposing sanction.”
86 FR 13876-86
Published 03-11-2020
