FAILURE TO TIMELY REPORT SALES TO AN EMBARGOED COUNTRY Sample Clauses

FAILURE TO TIMELY REPORT SALES TO AN EMBARGOED COUNTRY. PWC export personnel knew that the United States had imposed an embargo on sales or transfers of defense articles to China, that the HSC EEC software that had been modified for the initial military application required an export license from the Department of State, and that the HSC EEC software had been sold or transferred to China for installation in 67C engines for the Z10 helicopter. HSC personnel became aware of the same facts by at least early 2004. Notwithstanding that knowledge, PWC and HSC did not timely report the sale or transfer of the modified EEC software to DDTC as required by the ITAR. Rather, the report was not made until July 2006, several years after such sales or transfers had occurred, and nearly two and one half years after PWC’s Export Manager had written that HSC could no longer participate in the program because a U.S. export license would be required and the State Department would not issue one.
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