The Commerce Department’s Export Administration Regulations require licenses for export of certain scrap metals – elemental boron, beryllium, hafnium, zirconium containing hafnium and enriched lithium – to a host of countries large and small, nuclear armed and not, from Afghanistan to Zimbabwe, by way of Aruba, Gabon, Mauritius, India, Israel and Pakistan. But the scrap metal sent by General Logistics International to the latter was none of these: It was just scrap steel, EAR99 all the way.
Still, GLI is now paying a $90,000 penalty because the Pakistani entity it sent the steel to – People’s Steel Mills – is named in the Commerce Department’s “Entity List”, Supplement No. 4 to Part 744 of the Regulations. And it’s unlawful for any US entity to facilitate any kind of export transaction with any entity listed on the Entity List, even if the commodity exported is pencils.
So a word to the wise: Always check the Entity List before exporting anything – even scrap steel.