Opinion for the Court filed by Circuit Judge HARRY T. EDWARDS.
HARRY T. EDWARDS, Circuit Judge:
On April 19, 1984, the United States Department of Commerce ("the Department") charged Brian Moller-Butcher and M.E.S. Equipment, Inc. (a company controlled by Moller-Butcher) with multiple violations of the Export Administration Act of 1979, 50 U.S.C. App. §§ 2401-2420 (1988) ("EAA"). Moller-Butcher failed to answer the charges and, on February 19, 1986...
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