and reseller of electronic components located in Dubai, UAE. The company utilized a network of organizations and individuals who routinely redirected US origin goods and technology to end-users located in Iran. In 2005, components sold to Mayrow from a US exporter were found in an unexploded roadside bomb in Iraq. At the time, the exporting company was not required to apply for a license, as the goods were below export control thresholds. BIS responded by issuing General Order No. 3 in Part 736 of the Export Administration Regulations, which imposed a license requirement for goods and technology exported or re-exported to the individuals and companies which comprised the Mayrow General Trading Network. Later, this order was superseded by adding the parties to the BIS Entity List. These administrative actions allowed OEE investigators to interdict goods intended for diversion to Iran, identify 75 subjects involved in the procurement of these goods, and help industry to identify and stop illicit transactions intended for diversion by the network. Xun Wang, PPG Paints Trading Shanghi and Huaxing Construction From 2006 through 2007, Chinese companies PPG Paints Trading Shanghai Co Ltd, Huaxing Construction Co Ltd., and Xun Wang, Managing Director of PPG Paints Trading, conspired to provide high-performance epoxy coatings from the US for use in the construction of the Chashma II Nuclear Power Plant in Pakistan. Chashma II is owned by the Pakistan Atomic Energy Commission, which appears on the BIS Entity List. The epoxy coatings were transshipped via a third party in the People's Republic of China without the required export license. In December 2012, Huaxing Construction pled guilty and as part of its plea agreement, agreed to pay the maximum criminal fine of $2 million, with $1 million suspended if no further violations occur during the five years of probation. Under the terms of a related civil settlement, Huaxing Construction also agreed to pay another $1 million, implement an export compliance program, a five-year Denial Order suspended if no further violations occurring during that period, and be subject to multiple third-party audits over the following five years. Xun Wang also pled guilty and was sentenced to 12 months in prison, a $100,000 criminal fine, and one year of probation. Under the terms of a related civil settlement, Wang also agreed to pay a civil penalty of $250,000 (with $50,000 suspended), and to be placed on the Denied Persons List for a period