Epsilon Electronics, Inc. v. United States Department of Treasury
United States Court of Appeals for the District of Columbia Circuit
857 F.3d 913 (2017)
- Written by Tanya Munson, JD
Facts
In response to Iran’s support for terrorism, President Clinton imposed trade sanctions against Iran by executive order. The executive order was implemented by the Office of Foreign Assets Control (OFAC) of the Department of the Treasury (plaintiff) by promulgating the Iran Transactions and Sanctions Regulations (the regulations). The regulations prohibited United States individuals or businesses from exporting, reexporting, selling, or supplying, directly or indirectly, any goods, technology, or services to Iran. Exportation to a third country with the knowledge that the goods were intended specifically for reexportation to Iran was prohibited. OFAC began investigating Epsilon Electronics, Inc. (Epsilon) (defendant) after learning that Epsilon was doing business with Asra International (Asra). OFAC suspected Asra was intending to reexport Epsilon’s goods to Iran. OFAC sent Epsilon a letter explaining the prohibition and sent an administrative subpoena requesting details about Epsilon’s dealings with Asra and Iran. OFAC investigated Epsilon and discovered public information on Asra’s website and correspondence between Epsilon and Asra that allowed OFAC to conclude that Epsilon knew, or had reason to know, that Asra intended to reexport the goods to Iran. OFAC concluded that each of Epsilon’s shipments to Asra violated the regulations and issued a penalty notice imposing civil sanctions. Epsilon denied any knowledge or reason to know that Asra distributed Epsilon’s products in Iran and sued OFAC in district court. Epsilon sought declaratory and injunctive relief against the enforcement of the penalty. The district court granted summary judgment in favor of the government. Epsilon appealed.
Rule of Law
Issue
Holding and Reasoning (Griffith, J.)
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