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ARTICLE · 02 JULY 2024

Doing No Harm But Exporting Without Appropriate License Can Violate Regulations

Duane Morris LLP
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On June 24, 2024, the Department of Commerce's Bureau of Industry and Service (BIS) imposed an administrative penalty on Indiana University (IU) as part of a settlement agreement following IU's

United StatesInternational Law

On June 24, 2024, the Department of Commerce's Bureau of Industry and Service (BIS) imposed an administrative penalty on Indiana University (IU) as part of a settlement agreement following IU's discovery and self-disclosure to BIS that its Bloomington Drosophila Stock Center engaged in the export of materials that violated the Export Administration Regulations. IU's violations stemmed from its export of biological and genetic material without the proper license under the BIS.

The exports at issue involved genetically modified drosophila expressing transgenes that encode a component of the toxin ricin known as ricin toxin A chain. Drosophila, or the fruit fly, is a common model organism in genetic research because of its simple genetic makeup that consists of only four chromosomes and a short life cycle allowing for rapid reproduction for studies. Ricin is a ribosome inactivating protein that halts protein synthesis to produce its toxic effects. The toxin is comprised

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