In this episode we look at the recent BIS settlement with Bosch and warn against the dangers of relaxing Export Compliance vigilance when dealing with EAR99 Products.

https://www.bis.gov/press-release/robert-bosch-gmbh-bosch-pay-36-million-penalty-bis-violations-pertaining-shipments-huawei

https://www.justice.gov/opa/pr/national-security-division-announces-first-declination-under-department-wide-corporate

https://www.bis.gov/regulations/ear/734#section-734.9

In this episode we take another look at real cases involving export compliance. Where last episode we focused on the success of due diligence and compliance procedures, this episode focuses on where companies failed to follow export regulations and their violations resulted in penalties from BIS. The importance of end use/user checks and reviewing red flags cannot be overstated!

https://www.bis.gov/press-release/bis-reaches-administrative-enforcement-settlement-coastal-pva-technology-inc.

https://www.bis.gov/press-release/bis-reaches-administrative-enforcement-settlement-solventum-corporation-order

In this episode I break down a recent DOJ case involving Export Compliance, showing how the due diligence of U.S. manufacturers and exporters prevented the unlawful diversion of U.S. AI Technology to China. I also take a look at BIS's plans for Export Enforcement, and how our view on enforcing penalties and encouraging compliance is evolving.

https://docs.house.gov/meetings/FA/FA19/20260224/118974/HHRG-119-FA19-Wstate-PetersD-20260224.pdf

https://www.justice.gov/opa/pr/chinese-national-and-two-us-citizens-charged-conspiring-smuggle-artificial-intelligence