Case Document 1

Filed 07/10/19 PageID.1 Page 1 of 3

5911119291% JUL 10 12:112:

msnacrcousr


UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF 

January 2019 Gran? Jury

UNITED STATES OF AMERICA,
Plaintiff,
v.
QINGSHAN LI,

Defendant.

. .. my?.

5 6 4 3A3

Case No

 

IN 

[a
I:
Im

a

3.1453

Tit1e?22, U. S.

Secs. 2778(b)(2 and and
Title 22, CFR, Secs. 121.1, 123.1,
Attempt to Export

Defense Articles Without a License

 

 

The grand jury charges:

At all times relevant to

indicated:

this Indictment, unless otherwise

1. Defendant QINGSHAN LI was a national of the People?s Republic

Of China 





Diegoz7/9/19

 

 

 

Case Documentl Filed 07/10/19 PageID.2 Page20f3

THE ARMS EXPORT CONTROL ACT

2. The export of defense articles was regulated by the Arms Export
Control Act, Title 22, United States Code, Section. 2778 
Section 2778(a) authorized the President of the United States to control
the import and export of defense articles and to establish a United
States Munitions List which identified and defined the defense
articles subject to these controls. Section 2778(b) provided that any
person engaged in the business of manufacturing or exporting any defense
articles shall register with the government. Section 2778(c)
established criminal penalties for any willful violation of Section 2778
or any rule or regulation thereunder.

3. The United States Department of State ("the State Department")
implemented these statutory provisions by adopting the International
Traffic in Arms Regulations Title 22, Code of Federal
Regulations, Parts 120 et seq. These regulations established the USML
and required an export license for the export of any items on the list.
With limited exceptions for the closest military allies of the United
States, any export of items contained on the USML outside of the United
States required the issuance of a license by the State Department prior
to export or re?export.

4. Under 22 C.F.R. 127.1 it was unlawful to export or attempt
to export from the United States any defense article on the USML without
a license from the Directorate of Defense Trade Controls at the
State Department.






 

 

 

Case Documentl Filed 07/10/19 PageID.3 Page30f3

Count 1

5. On or about June 29, 2019, within the Southern District of
California, defendant QINGSHAN LI knowingly-and willfully attempted to
export from the United States to the PRC a defense article, that is, a
Harris Falcon 152A Radio (?the Radio"), which is designated
as a defense article on the United States Munitions List, without having
first obtained from the State Department a license or written
authorization for such export. I

All in violation of Title 22, United States Code, Sections 2778(b)(2)

'and 2778(c), and Title 22, Code of Federal Regulations, Sections 121.1,

123.1, and 

DATED: July 10, 2019.

  

 

 


Foreperson

ROBERT S. BREWER, JR.
United States Attorney

19.11%

EDEN N. PARMLEY
ELEXANDRA F. FOSTER
Assista Attorneys

?ne,


Urial Attorney, National Security Division_
Department of- Justice