The Minnesota Mining and Manufacturing (3-M) Co. of St. Paul has agreed to pay civil penalties of $137,500 for a total of 230 alleged violations committed by the parent company and nine subsidiaries of U.S. laws against the Arab boycott of Israel, the Department of Commerce announced.
Out of the total fine, $80,000 is for late reporting or failure to report 133 instances of alleged violations and $57,500 is for supplying prohibited information about the sale of U.S. goods to Middle East buyers in 97 alleged instances.
In addition, the 3-M organization agreed to strengthen its existing anti-boycott compliance program related to the provisions of the U.S. Export Administration Act.
VARIOUS SUBSIDIARIES INVOLVED
In making the announcement, the Department of Commerce pointed out that these alleged violations were “voluntarily brought to the attention of the Office of Anti-Boycott Compliance” of the Department of Commerce by 3-M.
The alleged violations implicated 3-M itself, its subsidiary, 3-M-Middle East in St. Paul, the Bird Corp. in Palm Springs, Calif. and the following subsidiaries overseas: 3-M Deutschland in West Germany; 3-M Belgium; 3-M United Kingdom; 3-M Middle East in Nicosia, Cyprus; 3-M Nederland; 3-M Italia; and 3-M France.
According to the Commerce Department, the parent company itself transferred U.S. produced goods from St. Paul to Bahrein, Saudi Arabia, Iraq, Kuwait and Egypt in the period Feb. 27, 1978-Feb. 6, 1979 that created alleged violations of the law.
STATEMENT BY U.S. FIRM
Dan Hitt, assistant general counsel for 3-M in St. Paul, said in a statement made available to the Jewish Telegraphic Agency here that “We are pleased that the Commerce Department saw fit to note 3-M’s cooperation throughout the investigation, reflecting the fact that every shred of information bearing on the settlement was discovered and volunteered by 3-M.”
“Nearly all of the substantive violations did in fact occur at a small European facility that was dealing with Middle East customers only because normal 3-M operations in Lebanon were disrupted by fighting in Beirut,” Hitt said. “The people involved were unaware of the company’s policy and U.S. regulations because they normally were not involved in transactions of this kind.”
Hitt pointed out that “outside the U.S., 3-M has nationals in 50 countries handling more than a quarter of a million invoices a month. We chose this settlement rather than face the potential for long and costly litigation, ” he said. “Part of the problem stems from a fine point of the law. It is lawful, for example, to say on an invoice where goods were made but it is illegal to state that the goods were not made in a boycotted country.” He emphasized that “There should be no question as to our policy” which is “to comply with all appropriate foreign laws and all U.S. laws affecting overseas commerce.”
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