Five employees of Sig Sauer GmbH have been indicted by the public prosecutor in Kiel, Germany and charged with violating the German Foreign Trade Act. The indictment stems from allegations that Sig Sauer GmbH illegally exported approximately 36,000 pistols to the Colombian National Police during the period from 2009 to 2012. During that time, Colombia was involved in a civil war with the Revolutionary Armed Forces of Colombia—People’s Army (“FARC”) and other guerilla groups, and the German Federal Office of Economics and Export Control would not approve the export of firearms to Colombia. According to the indictment, Sig Sauer GmbH deliberately exported the pistols to its U.S. subsidiary, Sig Sauer, Inc., which, in turn, exported them to Colombia, to avoid Germany’s ban on exports to Colombia. In order to obtain approval to export the pistols to Sig Sauer, Inc., Sig Sauer GmbH would have been required to obtain an end-user certificate and represent to the German government that the pistols were intended for sale to either governmental entities and/or the commercial/civilian market in the United States. The indictment charges that approximately 70,000 pistols were exported to Sig Sauer, Inc. for resale in the United States, but more than half of those 70,000 pistols were exported to Colombia for use by the National Police.