On August 24, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $1 million settlement with Ohio-based Container Manufacturing Ltd. (CML) to resolve allegations that the company exported restricted industrial parts to Russia without authorizations required under the Export Administration Regulations (EAR). According to BIS, the violations occurred between March 2023 and March 2025, and included parts valued at approximately $265,000. Notably, two of the shipments involved violations made with knowledge, which may explain a penalty amount nearly four times the value of the underlying transactions.
Continue Reading BIS Settlement Highlights Russia Export Control Risks for EAR99 Items and Third-Country Transactions
BIS Settlement Highlights Export Control Risks for Medical and Research Technology
On August 14, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Plexon, Inc., a Texas neuroscience technology company. BIS asserts that Plexon exported neural recording systems to a restricted Chinese research institution without appropriate authorization under the U.S. Export Administration Regulations (EAR). The EAR is the set of regulations that control exports of U.S. dual-use items; BIS is the main government agency responsible for administering and enforcing the EAR.
Continue Reading BIS Settlement Highlights Export Control Risks for Medical and Research Technology
DOJ Issues First Corporate Enforcement Policy Declination: Lessons from Bosch’s FDPR Export Control Resolution
On June 17, the U.S. Department of Justice (DOJ) National Security Division (NSD) announced its first declination under the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), declining to prosecute Robert Bosch GmbH (Bosch) for potential criminal violations of the Export Control Reform Act (ECRA).
Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to China
On February 11, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement with Applied Materials, Inc. (AMAT) and Applied Materials Korea, Ltd. (AMK) resolving allegations that the companies illegally reexported U.S.-origin semiconductor manufacturing equipment to China.
Continue Reading Export Enforcement Update: Huge Penalty Imposed for Semiconductor Re-Exports to ChinaExport Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty
On January 7, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Order resolving allegations that Exyte Management GmbH (Exyte), a Germany-based company, committed 13 violations of the Export Administration Regulations (EAR) in China. The violations were committed by Exyte’s Chinese affiliate, Exyte Shanghai Ltd (Exyte China).
Continue Reading Export Enforcement Update: EAR99 “In-Country” Transfers Lead to PenaltyUPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China
On October 30, U.S. Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will delay the implementation of the recently announced BIS Affiliates Rule for one year.
Continue Reading UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-ChinaBIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities
Please note that the content below was posted on October 2, 2025. We have since provided updated guidance on the topics discussed in this post here.
On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities and referred to by BIS as the “Affiliates Rule,” the rule is designed to close a longstanding loophole by extending restrictions to foreign affiliates of parties already subject to export restrictions, including those parties designated on the Entity List and the Military End-User (MEU) List.
Continue Reading BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed EntitiesHuge Export Penalty for U.S. Technology Company
On July 28, various arms of the U.S. government announced concurrent export enforcement resolutions involving Cadence Design Systems, Inc. (Cadence), a California-based software and technology firm. Cadence will pay over $140 million in combined net criminal and civil penalties and forfeiture.
Continue Reading Huge Export Penalty for U.S. Technology CompanyHaas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil liability related to multiple violations of the Ukraine-/Russia-related Sanctions Regulations and the Export Administration Regulations (EAR).
Continue Reading Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR ViolationsJoin Us: 2023 Export Year in Review Webinar
In 2023, U.S. export officials were busy bringing novel enforcement actions, introducing new and far-reaching rules, and issuing guidance (and warnings) to the exporting community. We can expect 2024 to be similar.
Join us for an insightful webinar where Thad McBride and Faith Dibble – international trade attorneys at Bass, Berry & Sims – will delve into the noteworthy enforcement actions of 2023.Continue Reading Join Us: 2023 Export Year in Review Webinar