Invitrogen and the Bureau of Industry and Security (”BIS”) recently signed a settlement agreement pursuant to which Invitrogen agreed to pay $30,000 for three shipments and one attempted shipment of human leukocyte antigen tissue typing trays to Syria without a license. The shipments and attempted shipments had been made, and voluntarily disclosed, by Dynal Biotech, which Invitrogen acquired in 2005. The charging documents allege that these shipments and alleged shipments violate General Order No. 2 of Part 736 of the Export Administration Regulations which forbids exports of all items “except food and medicine” to Syria.
