Switzerland – publishing SECO’s five most recent fines for sanctions breaches

Back in July we published a post highlighting that Switzerland’s SECO had imposed 5 new fines for sanctions breaches.

Through a Freedom of Information request we have obtained anonymized and redacted copies of these five Final Administrative Criminal Decisions.

These five decisions, and machine-generated translations are provided below, as well as summaries of the enforcement actions. The numbering sequence from when this blog published the previous 10 decisions is continued.

As previously, the value of the fines are all fairly low and these five cases combine for a total of CHF 13,490.

11. Final administrative criminal decision, dated 19 February 2024

Original: 2024-02-19-I.77-Strafbescheid.pdf

Translation: 2024-02-19-I.77-Strafbescheid_Translation.pdf

This case concerned the attempted export of CHF 10,569.90 of electrical switches to Russia. The export was stopped at Zurich Airport Customs in December 2023.

The goods in question had been included on the Swiss sanctions list as of 25 January 2023.

The company claimed it was unaware the goods were sanctioned, and SECO accepted this finding that the export was negligent rather than intentional.

In light of the company’s cooperation, and the company being able to show a track record of refusing sales to Russia which they knew were sanctioned, SECO set the fine at CHF 750, plus CHF 250 in costs.

The goods in question were returned to the seller.

12. Final administrative criminal decision, dated 26 February 2024

Original: 2024-02-26-I.78-Strafbescheid.pdf

Translation: 2024-02-26-I.78-Strafbescheid_Translation.pdf

This case concerned the attempted export of €57,263 worth of pressure transmitters, pressure transducers and pressure gauges to Russia. The export was stopped at Zurich Airport Customs in December 2022.

The goods in question had been added to the Swiss sanctions list during November 2022.

SECO had earlier written to the company, in 2021, to say that the export of the goods could be done without a licence, subject to the changing requirements of Swiss sanctions.

SECO accepted the argument that the export was not intentional, but found it was negligent and that the company should have been more aware of the sanctions in place.

In light of the company’s cooperation, SECO set the fine at CHF 2,900, plus CHF 970 in costs.

The goods in question were returned to the seller.

13. Final administrative criminal decision, dated 26 February 2024

Original: 2024-02-26-I.67-Strafbescheid.pdf

Translation: 2024-02-26-I.67-Strafbescheid_translation.pdf

This case concerns two attempted exports of spare parts for medical and dental devices to Russia. Within wider sales of nearly €27,000 worth of parts, sanctioned goods with a value of approximately €3,600 were included.

On both occasions the goods were stopped by customs.

The company sought to explain the two prohibited exports by saying that the wrong HS code had been entered into its internal system (9026.2000 instead of 8481.1010) and so it had not been caught by its systems. In the other instance the company said it searched for the HS code using the format in the customs tariff (which used a full-stop in the number), while in the relevant Appendix in the Ordinance the HS code used a space instead of a full stop. The company’s searches against its products therefore resulted in false negatives and the shipments were incorrectly authorised.

The company relied heavily on its detailed procedures and training as mitigation, and had appointed an outside consultant to assist further with compliance. In addition, the company sought a retrospective approval for the exports on humanitarian/medical grounds.

SECO denied that request saying “a retroactive authorization cannot be issued to regularize exports”.

While not alleging an intention to breach the sanctions, SECO decided that the company had been negligent and commented that a “more precise check” of the prohibited codes would have prevented the export. It is as good an example of the importance of fuzzy searching as you’ll find.

The company was fined CHF1,000 and costs of CHF590. The seized goods were returned to the company.

14. Final administrative criminal decision, dated 11 March 2024

Original: 2024-03-11-I.79-Strafbescheid.pdf

Translation: 2024-03-11-I.79-Strafbescheid_Translation.pdf

This case concerned two blocked exports of goods valued at €2000 which were stopped by the Zurich Customs office. The goods included foam generators and level sensors.

In the first example the attempted export took place on the same day as the respective goods were announced as being added to the lists of prohibited items. The version of Annex 23 to the Ordinance had been updated on SECO’s website, but not on other versions. Nonetheless, SECO determined that the export fell under the heading of “negligent”.

In the second example, the company argued that the prohibition against certain goods which are “suitable for use in the aerospace industry” could be negatived by evidence that this was not going to be the actual use. SECO disagreed.

The company was fined CHF2,300 and ordered to pay costs of CHF970. The seized goods were returned to the company.

15. Final administrative criminal decision, dated 13 March 2024

Original: 2024-03-13-I.76-Strafbescheid-002.pdf

Translation: 2024-03-13-I.76-Strafbescheid_translation.pdf

This case concerned a shipment of 8,640kg of products with customs code 3824.9919 valued at €19,612.80.

The goods were seized by the St. Gallen customs office in October 2022.

The company claimed that it had no knowledge that the goods in question were subject to Switzerland’s Russian sanctions.

SECO’s response was to state:

However, it is not the actual knowledge of the persons concerned of the criminal nature of the sale and export transaction that establishes criminal liability, but it is sufficient if the knowledge of the criminal liability should have been present in the company with due diligence. This must be affirmed in the present case.”

SECO accordingly concluded that the company was guilty of a negligent breach of sanctions.

A fine of CHF2,800 was imposed and costs of CHF960. The seized goods were returned to the company.

Switzerland – investigation into suspected breaches of Russian asset freeze

It is being reported that the Office of the Attorney General in Switzerland has opened criminal and administrative proceedings as part of investigations into suspected breaches of the asset freeze imposed on Suleyman Kerimov under Swiss sanctions.

It is being reported that SECO has confirmed that the criminal proceedings were commenced in November 2023 and that four individuals are under suspicion, as well as that eight premises have been raided so far.

Assets worth SWF 1.3 billion have also been made subject to a “super-provisional” asset freeze.

Switzerland – updated sanctions enforcement statistics with 5 new fines

Switzerland’s SECO has updated its Russian and Belarusian sanctions enforcement statistics. The previous update was in February 2024 (see our previous post).

The reported new data states that SECO has brought:

    • 56 administrative criminal proceedings (up from 47 in February);
    • 41 of which have been finalized (up from 29 in February);
    • including 26 discontinuation orders (up from 20 in February);
    • 14 penalty notices (up from 9 in May when these were published on this blog here, here, here and here); and
    • 1 penalty order (this is case 6 previously published on this blog here).

Accordingly, SECO has started 9 new criminal administrative proceedings since February 2024, and imposed 5 new fines since May of this year.

 

Switzerland – publishing the 10 fines for breaching sanctions imposed by SECO: Part 4 – cases 9-10

This is the fourth and final instalment of making public the final administrative criminal decisions imposed by SECO in relation to breaches of the Swiss sanctions against Belarus and Russia.

9. Final administrative criminal decision dated 20 November 2023

Original: 2023-11-20 – I.65 – Strafbescheid

Translation: 2023-11-20 – I.65 – Strafbescheid_Translated to English

The company in question imported a dismantled wooden sauna, and accompanying parts, from a Belarusian company via Kyrgyzstan valued at €3,000. Geneva Rive-Droite customs stopped the importation.

An investigation was commenced on the basis that the products met the criteria for wood products (customs code 4418.9900) rather than the customs code used by the importer which related to prefabricated building structures (customs code 9406).

SECO obtained a ruling from the Federal Customs Office that the goods did indeed fall under the code for wooden products with the other parts being irrelevant as they had no impact on price, and that the customs code for prefabricated buildings was not relevant to a sauna which was to be installed internally rather than as a stand alone structure.

SECO took the view that the breach was negligent and resulted from a breach of the duty to conduct “additional checks on the classification of products prior to the conclusion of a purchase contract with a company based in Belarus” rather than deliberate and given the low value of the goods imposed a fine of CHF 1,000 plus CHF 580 in costs.

Comment: The use of the prohibition against importing “wood products” from Belarus to cover finished items made from wood is noteworthy.

10. Final administrative criminal decision dated 15 January 2024

Original: 2024-01-15 – I.73 – Strafbescheid

Translation: 2024-01-15 – I.73 – Strafbescheid_Translated to English

The company in this case sought to export polyethylene products some of which were prohibited (customs code 3920.10) and some of which were not (*customs code 3916.10) from export to Russia. The value of the prohibited goods was €5,373.

The shipment was stopped by customs at Zürich airport. An investigation was started and the company admitted the facts stating that it had “not even considered that the delivery of polyethylene sheets could fall under the Ukraine Regulation“.

SECO accepted that the breach was negligent and not intentional, and in light of the early cooperation, the low value of the breach, and the provisions of Swiss law permitting the corporation to pay a fine of CHF 5,000 or less rather than investigators seeking to identify culpable individuals, the fine imposed was CHF 2,500 plus costs of CHF 1,260.

Comment: In this case the company gave the name of “the person responsible for the alleged facts”. SECO, however, took the view that this admission was insufficiently detailed to be relied upon for the purpose of imposing personal criminal liability and a fine on that individual.

Switzerland – publishing the 10 fines for breaching sanctions imposed by SECO: Part 3 – cases 7-8

This is the third  instalment in our series of publishing the 10 final administrative criminal decisions reached by SECO in Switzerland. The examples below relate to Russian and Belarusian sanctions.

7.   Final administrative criminal decision dated 19 September 2023

Original: 2023-09-19 – I.60 – Strafbescheid

Translation: 2023-09-19 – I.60 – Strafbescheid_Translated to English

This final decision relates to a company which sought to export to Belarus an embossing roll used in the embossing of cigarette packaging. The value of the products was stated as €21,300. The products were stopped at Zürich airport customs and an investigation was commenced.

The company sought to argue that, while its product was covered by the customs code annexed to the Swiss regulation it was not “machinery” and so not covered by the wording of the export prohibition contained in art. 6 of the Belarus Ordinance.

SECO disagreed saying that if the product was covered by the customs code included in the Annex then it was covered by the prohibition in the Ordinance itself but invited the company to seek (if it wished) a ruling as to whether an embossing roll fell within customs code 8420.9120.

The company sought that ruling and the FOCBS confirmed that the rolls were properly covered by that number.

The company then communicated to SECO that based on the company’s own view that its product was a part and not itself machinery “the only criticism that can therefore be made of our company is its interpretation of the regulatory provisions“.

SECO disagreed and found that the company was in negligent, but not intentional, breach of the sanctions with the company having “a responsibility to carefully analyse the embargo orders imposed by Switzerland and to take the necessary measures to avoid contravening them [and that] additional checks on the classification of its products before the conclusion of new orders to Belarus were reasonably required“.

SECO, however, determined that the appropriate course was reliance on the provisions permitting a fine of CHF 5,000 or less in order to avoid a disproportionate investigation to determine individual culpability.

The company was also given credit for cooperation and was fined CHF 3,000 plus CHF 1,070 in costs.

Comment: Given that the company said it carefully analysed the regulations in question and that it sought to rely on what it saw as an inconsistency between the customs codes listed in the Annex which attached to their products, and the company’s narrow reading of the wording of the prohibition in the Ordinance, a regulator or prosecutor might have been entitled to conclude that the breach was intentional. The company knew that the product code attached to its goods was barred from export to Belarus.

There is also scope for querying the mitigation credit for cooperation in the circumstances of this investigation.

8.   Final administrative criminal decision dated 28 September 2023

Original: 2023-09-28 – I.71 Strafbescheid

Translation: 2023-09-28 – I.71 – Strafbescheid_Translated to English

The company sought to export 700 rubber seals (customs code 4016.93) and 3,750 valves (customs code 8481.20) to Russia. The products were stopped by customs at Geneva Airport in December 2022. The goods were valued at €69,315.

On 1 January 2022 the company had written to SECO to obtain advice on whether it could export its products to Russia. It was not until 2 June 2022 that SECO replied stating that the products were prohibited from export to Russia but that for contracts which pre-dated 28 April 2022 there was a sunset provision enabling export up until 29 July 2022.

Further, because the products were for use in prosthetic knees, there was a licence exception for medical goods that was available.

Nonetheless the company proceeded to try and export the products in December 2022 without applying for the available licence.

After the commencement of the investigation the company applied for, and obtained a licence permitting export of the goods.

SECO emphasized that “a request for a derogation must have been submitted to SECO prior to any sale, delivery and export, and SECO must have granted the necessary approval. It is not possible to legalize the sale, supply or export of goods listed in Annex 23 unlawfully by an authorization granted on a retroactive basis. … The fact that the goods in question were issued at the beginning of February 2023 for a use in accordance with the law is irrelevant to the question of the lawfulness of the sale, delivery and export of the goods in December 2022“.

Despite the company having been told in writing that the unlicensed export of the products to Russia would certainly be prohibited after July 2022, SECO proceeded on the basis that the breach was negligent and not intentional.

The company was fined CHF 1,000 with costs of CHF 1,270.

Comment: Practitioners will note the clarity of the view from SECO as to the impossibility of retrospective authorisation.

It is also seems likely, however, that the medical nature of the products in question played a role in the generous conclusion of a negligent rather than intentional breach in the circumstances of this case.

 

 

Switzerland – publishing the 10 fines for breaching sanctions imposed by SECO: Part 2 – cases 4-6

Below is the second in our series of publishing the 10 final administrative criminal decisions reached by SECO in Switzerland. The examples below relate to Russian and Belarusian sanctions.

The final instalment will be published on Tuesday.

4.   Final administrative criminal decision dated 15 May 2023

Original: 2023-05-15 – I.45 – Strafbescheid

Translation: 2023-05-15 – I.45 – Strafbescheid_Translated to English

The company in question sought to export a wrist watch valued at CHF275,766. The export was marked as being for a person with an address in the Russian Federation. The shipment was blocked at Geneva Airport as being potentially in breach of the Swiss prohibition against exporting luxury goods.

The company sought to argue that the sale had taken place in 2020, but could provide no evidence of this, and sought to argue that the customer was resident in Dubai, but the residency document dated several months after the attempted export.

SECO noted that the prohibition covers, “sale, delivery and export”, and so the fact of a sale in 2020 (even if that was the date) did not stop the offence having been completed by virtue of the blocked export.

SECO, however, accepted that the breach was not intentional but was rather negligent but that it was unable to determine whether the breach was the result of “non-compliance with internal guidelines by the responsible employee …, insufficient implementation of these guidelines in the internal process, absence of such guidelines, insufficient and inadequate compliance structures, lax application of internal guidelines by the employee in charge, insufficient control of that person by his or her supervisor or a combination of all of these”.

As with the other fines previously published SECO chose to use the mechanism of imposing a fine of CHF 5000 or less rather than seeking to investigate the responsible individuals. SECO imposed a fine of CHF5,000 with costs of  CHF 1,280.

Comment: Given the relatively high value of the watch in question, and the reliance on evidence that was not exculpatory, the company in question may have achieved a result at the lower end of the scale of what might have been expected. Under Swiss law a negligent breach can attract a fine of up to CHF 100,000.

5.   Final administrative criminal decision dated 22 June 2023

Original: 2023-06-22 – I.61 – Strafbescheid

Translation: 2023-06-22 – I.61 – Strafbescheid_Translated to English

The company sought to export 10,583.9 kg of food colouring valued at €47,000 to Russia. The goods were stopped at St Margrethen custom office and an investigation was commenced.

The company admitted the facts, but stated it “had assumed the sale of food colours to a company domiciled in the Russian Federation is permitted”. As stated by SECO: “It is not clear on what basis it came to that conclusion at the time”.

Nonetheless, SECO concluded that “the conduct of the accused constitutes imprudence in breach of duty and is to be qualified as negligent” rather than intentional conduct. SECO also noted that the “execution of the export transaction by the accused is due to a chain of unfortunate circumstances” but provides no further detail on this point.

SECO again used the mechanism of imposing a fine of CHF 5,000 or less noting that “it is hardly possible to reconstruct who ultimately authorized the transaction”. The fine was CHF 4,500 plus costs of CHF 1,260.

SECO noted the company’s co-operation and early admission of the facts.

Comment: one of the justifications cited by SECO for using the CHF 5,000 fine option and not conducting further investigations was that it would be “disproportionate in view of the penalty forfeited”. This is circular reasoning. The size of the fine should not be reason for the size of the fine.

Given that the company appears to have undertaken no due diligence or investigation of any sort before seeking to export to Russia it is, perhaps, a surprising result that SECO chose to impose the fine that it did.

6.   Final administrative criminal decision dated 4 September 2023

Original: 2023-09-04 – I.49 – Strafverfügung

Translation: 2023-09-04 – I.49 – Strafverfügung_Translated to English

This document takes a slightly different format as the company in question challenged the original penalty notice of CHF 7,810 and costs of CHF 1,290, which was then subsequently upheld.

The company was the authorized consignor for 10 shipments to Russia and one to Belarus. All but one of these were stopped by customs. After the opening of the investigation a further two shipments from this company which were due to be exported to Russia were stopped.

The total value of the goods was said to be CHF 15,619.18, but six of the exports were said to have the exact value of CHF 1,000 which permits some suspicion as to the declared values. The goods were a mixture of parts for luxury branded cars, and other luxury goods such as clothing, a musical instrument and a laptop.

The company sought to argue that no offence had been committed as all that it did was transport goods within Switzerland, and that at most all that could be said was that there was an attempt to export.

SECO disagreed and stated: “In order to complete the deed, it is not required that the goods must have reached the country of destination. Since consignments of goods destined for export and delivery to the Russian Federation or, in one case, to Belarus … constitutes prohibited transport within the meaning of” the respective regulations.

SECO alleged that the company had a “duty of care of a customs declarant to check whether there are any prohibitions, restrictions or conditions in relation to a consignment of goods” and that it had an “increased duty2 due to its status as a “Authorised Consignor”. Nonetheless, SECO did not alleged intentional breach of the regulations (even for those done after the commencement of the investigation) but rather negligent breaches. SECO also concluded that the breaches were not “outliers” as 12 of the breaches took place in just five months.

SECO imposed a fine of CHF 7,810 and costs of CHF 1,310.

Comment: The clarification on SECO’s views as to what constitutes “transport” and that this can be committed even through actions wholly internal to Switzerland is to be welcomed.

The lack of an allegation of deliberate breach is perhaps surprising in the circumstances, as is the giving of credit for cooperation given that conduct continued during the investigation and the initial fine was contested.

Switzerland – publishing the 10 fines for breaching sanctions imposed by SECO: Part 1 – cases 1-3

Below is the first in our series of publishing the 10 final administrative criminal decisions reached by SECO in Switzerland. The examples below relate to Russian and Belarusian sanctions.

The next instalment will be published on Monday.

1.   Final administrative criminal decision dated 21 November 2022

Original: 2022-11-21 – I.41 – Strafbescheid

Translation: 2022-11-21 – I.41 – Strafbescheid_Translated to English

The company in question attempted to export 1,850kg of a kind of lubricant (customs code 3403) included in the list of banned exports from Switzerland to Russia. The value of the products was €17,440.

The goods were stopped by Swiss customs at Mendrisio. An investigation was commenced.

The company cooperated and admitted the breach but submitted in writing that it was unaware that the product was included on the sanctions list.

SECO accepted this evidence and undertook its assessment of the penalty based on the fact that the breach was negligent and not intentional. This distinction gives rise to significantly different penalties under Swiss law.

A negligent breach can give rise to a maximum penalty of CHF 100,000 and/or a custodial sentence of up to three months.

Given the low value of the breach, and the accepted evidence of negligence rather than intent, SECO relied upon a provision of Swiss criminal procedure whereby if a fine is of no more than CHF 5,000 then the company can pay the fine without the need for further investigation to determine the specific individuals responsible. This was said to be proportionate compared to the time and cost of a full-blown investigation.

In light of this a fine of CHF 4,500 was imposed plus costs of CHF 1,260.

Comment: while the result may be proportionate to the value of the goods, it is unclear from the final decision whether the company in question received the payment of €17,440. It may be hoped that if such payment had been received that those funds would have been confiscated.

It is also noteworthy that the investigation was commenced on 5 September 2022 and finished by 26 October 2022, with the final decision issued on 21 November. As described the defendant was able to make written submissions but no person was interviewed and no documents or other evidence was sought. The submission of negligent ignorance of the sanctions appears to have been accepted without being tested.

2.   Final administrative criminal decision dated 18 January 2023

Original: 2023-01-18 – I.42 – Strafbescheid

Translation: 2023-01-18 – I.42 – Strafbescheid_Translated to English

The company in question sought to export pumps (customs code 8413.9130) to Belarus valued at €39,619.20. Such goods are prohibited from sale, delivery or export to Belarus under article 6 of the Swiss Ordinance dated 16 March 2022. The goods were stopped at Zurich airport and had been due to arrive in Belarus after first being transported through Turkey and Russia.

The company accepted the breach, but submitted that it had obtained SECO clearance when the order was first placed in January 2022, but that it had mistakenly failed to re-check the tariff code against the Ordinance at the time of export in June 2022. The company also undertook remediation measures and appointed a sanctions compliance officer.

SECO accepted that the breach was not intentional, but stated that “as a company active in international trade, it had a duty to carefully analyse the embargo ordinances imposed by Switzerland and to take the necessary measures to ensure that they were not contravened“.

As with the earlier final decision, SECO relied upon the provision whereby a fine of under CHF 5,000 could be paid by the company without having to investigate the culpability of individual employees.

SECO considered as aggravating factors the value of the intended export and the fact that “more thorough control and monitoring” was expected of such a company. Mitigation consisted of the company’s cooperation, the remediation undertaken, and the fact that the export was not completed.

In light of this a fine of CHF 2,000 was imposed plus costs of CHF 560.

Comment: The case is a noteworthy statement of SECO’s expectation of a trading company’s duty to ensure compliance. Also noteworthy is the credit received for cooperation and remediation.

While one may wonder whether an export routed to Belarus through Turkey and Russia was intended as circumvention it appears that it was the company’s own customs declaration which indicated accurately both the nature of the goods and the destination. Accordingly, it is understandable why SECO took the view that the conduct was not intentional especially when combined with the fact that the company had earlier sought (and obtained) clearance for the export.

3. Final administrative criminal decision dated 1 May 2023

Original: 2023-05-01 – I.63 – Strafbescheid

Translation: 2023-05-01 – I.63 – Strafbescheid_Translated to English

The company in question attempted to exporte a painting valued at CHF 1,500 (i.e. a prohibited luxury good) to Russia, with the painting seized by the customs office at Mülligen.

An investigation was commenced as part of which the company admitted the alleged facts. The company, however, also noted that the painting had first been shipped to Moscow on 22 February 2022 (prior to the prohibition on the export of luxury goods) but that it had been returned to Switzerland undelivered as the customer was not at home at the time of the attempted delivery. By the time of the second attempted export in September 2022, the prohibition had come into place.

SECO accepted the company’s submission of a negligent rather than intentional breach noting, however, that the company “was obliged to examine more closely whether the export of the said goods to or for use in the Russian Federation was permissible“.

SECO availed itself of the same provisions allowing a simplified investigation where a company is fined CHF 5,000 or less. A fine of CHF 700 was imposed plus costs of CHF 370.

Comment: SECO noted the early admission of fault and the company’s cooperation, as well as the mitigating circumstance that the sale (when first conducted) had been lawful and that if the customer had been home at the first attempt there would have been no breach. Also noted was the low value of the breach.

The case is, however, illustrative of the expectations of due diligence and compliance expected by SECO even on a company that “is a family business and very rarely exports to Russia“, and that even a one-off, low value breach may still be the subject of investigation, conviction and fine.

Switzerland – publishing the 10 fines for breaching Russian and Belarusian sanctions imposed by SECO: an introduction

Today we start a series of posts in which we will be publishing anonymized versions of the ten final administrative criminal decisions issued by SECO as part of proceedings for breaching Russian, and Belarusian, sanctions in Switzerland.

The details of these proceedings, the conduct giving rise to the fines, the process of the investigations, and the level of the fines are all not otherwise public.

These anonymized final decisions have been obtained through a Freedom of Information request to SECO, and SECO has confirmed that these anonymized versions may be published or otherwise made available.

The blog is grateful for SECO’s assistance.

We will publish the first three decisions today, three more on Monday and the final four on Tuesday of next week.

As well as the final decisions themselves (some of which are in German and some in French), we will be publishing machine translations into English for convenience. We make no representation as to the accuracy of these translations. The blacked-out redacted text in the originals is shown as “REDACTED” in the translations.

European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.

 

© 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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