Opinion for the Court filed by Circuit Judge HARRY T. EDWARDS.
HARRY T. EDWARDS, Circuit Judge:
On December 22, 1988, the United States Department of Commerce ("the Department") charged Klaus Westphal with multiple violations of the Export Administration Act of 1979, 50 U.S.C. §§ 2401-2420 (1988) ("EAA"). Notice was given to Westphal, a resident of Germany, but he failed to answer the charges or request a hearing. On April 27, 1989, an Administrative...
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