Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
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Where?
by regionAll jurisdictions
What for?
by action- Fine €964.8m 100 % · 19 cases
Who?
by sectorAll sectors
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2023 | 2 | €293.3m |
| 2024 | 3 | €228m |
| 2025 | 3 | €124.6m |
| 2026 | 11 | €318.9m |
19 cases
24 Aug 2026 Container Manufacturing Ltd.Small US machinery supplier exported spare parts for can presses to Russia €857,339
Between March 2023 and March 2025, the Ohio manufacturer of presses for beverage can ends (nine employees) supplied, in ten instances, spare parts for aluminium forming tools worth around 264,700 USD – partly via the UAE and Turkey – without a licence to a Russian customer whose group also supplies defence precursors. In two instances, the company acted with knowledge of the violation; it admitted the allegations, which were brought by the US Commerce Department's Bureau of Industry and Security (BIS).
Even small businesses with few employees must check tariff codes against Russia restrictions and treat deliveries via third countries as a warning sign.
HTS-based export restrictions on Russia, diversion via third countries
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, § 746.8(a)(5) (HTS-Codes Supplement No. 4 to Part 746), §§ 764.2(a), 764.2(e)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- Under 50
- Mitigating circumstances
- Full cooperation; compliance programme subsequently expanded with screening, an approval process and additional export control training
- Published
- 24 Aug 2026
Original amount 1,000,000 USD, converted at the ECB reference rate of 24 Aug 2026.
- BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd. (24.08.2026) Press release of an authority
- BIS Order Relating to Container Manufacturing Ltd. Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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14 Aug 2026 Plexon, Inc.Plexon: brain research recording systems to listed Chinese military medical academy – 1.7 million USD suspended €1.47m
The neurotechnology company from Dallas, described by the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) as small, delivered neural data acquisition systems (“OmniPlex”) and accessories worth around 179,000 USD on eight occasions in 2022/23 via its Asian distributor to the Chinese Academy of Military Medical Sciences, which has been on the Entity List (the US export control list of restricted parties) since December 2021. The penalty of 1.7 million USD is suspended for five years and then waived, provided that Plexon submits an external audit of its export compliance programme on time and commits no further violations; a five-year denial of export privileges is likewise suspended, and Plexon must also provide export control training.
Screen orders placed via distributors against the Entity List before production – research equipment can also end up with listed military institutions.
Entity List screening for orders via distribution partners
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, 15 C.F.R. § 764.2(a), § 744.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Penalty and denial of export privileges fully suspended for five years, conditional on an external export control audit.
- Published
- 14 Aug 2026
Original amount 1,700,000 USD, converted at the ECB reference rate of 14 Aug 2026.
- BIS Reaches Administrative Enforcement Settlement with Plexon, Inc. Press release of an authority
- Order Relating to Plexon, Inc., Settlement Agreement und Proposed Charging Letter Decision of an authority
Checked against the official source on 28 Sep 2026 · Direct link
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4 Aug 2026 BAE Systems, Inc.DDTC: USD 36 million against BAE Systems for ITAR violations, including a China link €31.3m
The DDTC settled with BAE Systems, Inc. for a civil penalty of USD 36 million. The allegations concerned unauthorised exports and retransfers of defence articles to several countries, in one case to the People's Republic of China, the unauthorised furnishing of defence services and breaches of authorisation provisos. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments; the agreement requires, among other things, an external compliance audit. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Retransfers by recipients must be controlled contractually and organisationally just as strictly as one's own exports.
ITAR compliance: retransfers, defence services and authorisation provisos
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Mitigating circumstances
- The company reported the matters in voluntary disclosures and in response to a disclosure directed by the DDTC, and cooperated with the review.
Original amount 36,000,000 USD, converted at the ECB reference rate of 4 Aug 2026.
- U.S. Department of State, Order, In the Matter of BAE Systems, Inc. Decision of an authority
- U.S. Department of State, Consent Agreement, BAE Systems, Inc. Decision of an authority
- DDTC, Penalties & Oversight Agreements Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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30 Jul 2026 Airbus Operations LimitedAirbus Operations pays 6.4 million GBP for export control breaches in technology transfer €7.48m
Over an extended period before November 2022, Airbus Operations Ltd breached the Export Control Order 2008: transfers of controlled technology under three open general export licences (OGEL) were not correctly documented, required registers were missing, and one individual licence was not complied with. The case came to light through voluntary disclosure and was concluded by HM Revenue & Customs (HMRC) by way of a compound settlement (date of publication).
Technology transfers by e-mail or data room are also exports – conditions, registers and records of general licences must be put into practice day to day.
Licence conditions and record-keeping obligations in technology transfer
- Authority / court
- HM Revenue & Customs (HMRC) / Export Control Joint Unit
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Control Order 2008, Art. 29(2) und 29(3) (Auflagen und Register bei OGELs) sowie Auflage einer SIEL; Straftaten nach Art. 38(1)(a) und (b); Compound Settlement durch HMRC
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Mitigating circumstances
- Voluntary disclosure, full cooperation, remedial measures
- Published
- 30 Jul 2026
Original amount 6,409,388 GBP, converted at the ECB reference rate of 30 Jul 2026.
- Notice to exporters 2026/17: company named in compound settlement for breaches of export control Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Jun 2026 Robert Bosch GmbHBosch pays 36 million USD for sensor supplies to Huawei €31.2m
Between September 2020 and September 2024, Bosch exported MEMS sensors and vehicle software worth around 72.4 million USD from outside the US without a licence to Huawei and affiliated companies on the Entity List (Foreign Direct Product Rule). Bosch voluntarily disclosed the violations; around 3.6 million USD of the penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) is credited against a disgorgement agreed with the DOJ.
Even products manufactured outside the US can be subject to US export controls via US technology – supplies to Entity List customers need their own review.
US export law for foreign-made products (Foreign Direct Product Rule)
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations (Foreign Direct Product Rule, Entity List)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Automotive
- Employees
- 10,000 or more
- Mitigating circumstances
- Voluntary self-disclosure and cooperation
- Published
- 17 Jun 2026
Original amount 36,184,680 USD, converted at the ECB reference rate of 16 Jun 2026.
- BIS: Robert Bosch GmbH (Bosch) to Pay $36 Million Penalty for BIS Violations Pertaining to Shipments to Huawei (17.06.2026) Press release of an authority
- BIS Order Relating to Robert Bosch GmbH (16.06.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Apr 2026 General Electric CompanyDDTC: USD 36 million against General Electric for technical data exports to China €30.5m
The DDTC settled with General Electric Company for a civil penalty of USD 36 million for ITAR violations: unauthorised exports of technical data to the People's Republic of China, breaches of authorisation provisos, unauthorised exports of defence articles and failure to report material changes to its ITAR registration. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Changes to one's own ITAR registration must also be reported and belong in the compliance calendar.
ITAR registration and control of technical data with a China link
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Mitigating circumstances
- The allegations are based on facts that the company itself disclosed to the DDTC.
Original amount 36,000,000 USD, converted at the ECB reference rate of 17 Apr 2026.
- U.S. Department of State, Order, In the Matter of General Electric Company Decision of an authority
- DDTC, Penalties & Oversight Agreements Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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13 Apr 2026 Coastal PVA Technology, Inc.Coastal PVA: 1.7 million USD (suspended) for brushes sold to SMIC – without an export compliance programme €1.45m
The Californian manufacturer of PVA brushes for wafer cleaning sold goods worth around 400,000 USD on 18 occasions between 2021 and 2024 via two Chinese distributors to SMIC Beijing and SMIC North, both on the Entity List (the US export control list of restricted parties). The company had no formal export compliance rules; the penalty of 1.7 million USD is suspended for one year owing to limited ability to pay and will be waived if training and an internal audit are completed on time.
Obtain a licence even for unlisted everyday goods (EAR99) when the end customer is on the Entity List – without end-customer screening, routing sales through distributors does not help.
Export controls for EAR99 goods and deliveries via distributors
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, 15 C.F.R. § 764.2(a), § 744.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- negligent
- Mitigating circumstances
- Payment suspended owing to demonstrated limited ability to pay; deliveries stopped after notification by BIS (Bureau of Industry and Security).
- Published
- 14 Apr 2026
Original amount 1,700,000 USD, converted at the ECB reference rate of 13 Apr 2026.
- BIS Reaches Administrative Enforcement Settlement with Coastal PVA Technology, Inc. Press release of an authority
- Order Relating to Coastal PVA Technology, Inc., Settlement Agreement und Proposed Charging Letter Decision of an authority
Checked against the official source on 28 Sep 2026 · Direct link
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26 Feb 2026 Teledyne FLIR LLCTeledyne FLIR: thermal imaging cameras incorrectly assessed and supplied to Entity List address €846,453
The manufacturer of militarily relevant thermal imaging technology admitted 19 violations to the US Commerce Department's Bureau of Industry and Security (BIS): incorrect de minimis calculations for cameras that went to China via Sweden, pricing arranged with a Chinese drone manufacturer to circumvent the licence requirement, missing records and eight deliveries in 2024 to a Hong Kong address on the Entity List that the screening software did not detect.
Actively incorporate new forms of listing, such as address-only entries, into screening; do not rely solely on the software provider.
De minimis calculation, address-based Entity List entries in screening
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, §§ 734.4 (De minimis), 744.16, 764.2(a), (b), (h), (i)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Mitigating circumstances
- Voluntary self-disclosures for some of the violations
- Published
- 26 Feb 2026
Original amount 1,000,000 USD, converted at the ECB reference rate of 26 Feb 2026.
- BIS Reaches Administrative Enforcement Settlement with Teledyne FLIR LLC and its affiliates (26.02.2026) Press release of an authority
- BIS Order Relating to Teledyne FLIR LLC (26.02.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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24 Feb 2026 Vizocom ICTVizocom: blueprints for military antenna sent to China and copies supplied to the US Navy €317,971
The Californian dealer had won a Navy contract for 450 VHF/UHF antennas from a US manufacturer, but in 2019 uploaded the export-controlled production specifications of the purely military antenna without a licence to the portal of a Chinese manufacturer, had the antennas produced there for 6 USD each and supplied them to the Navy with false manufacturer information for 165,109.50 USD. The Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) imposed 374,474 USD in 20 instalments and a denial of export privileges suspended for five years.
Do not send specifications of military goods to foreign manufacturers without a licence – even uploading a drawing to a supplier portal is an export.
Technical drawings and specifications as export-controlled technology
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, 15 C.F.R. § 764.2(a), §§ 742.4, 742.6 (ECCN 3E611)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Culpability
- intentional
- Liability of senior managers
- Measures against individuals are not reported here.
- Published
- 25 Feb 2026
Original amount 374,474 USD, converted at the ECB reference rate of 24 Feb 2026.
- BIS Reaches Administrative Enforcement Settlement with Vizicom ICT Press release of an authority
- Order Relating to Vizocom ICT (24. Februar 2026) mit Settlement Agreement Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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11 Feb 2026 Applied Materials, Inc. und Applied Materials Korea, Ltd.Applied Materials pays 252 million USD for chip equipment exports to China €212.2m
In 2021 and 2022, Applied Materials and its Korean subsidiary exported ion implanters for semiconductor manufacturing worth around 126 million USD via Korea without a licence to a Chinese company placed on the Entity List in 2020. The penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) corresponds to twice the transaction value and thus the statutory maximum; the compliance staff and executives responsible are no longer with the company.
Routing through foreign subsidiaries does not remove the licence requirement; export control needs audits and clear accountability of management.
Entity List screening for deliveries via subsidiaries
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations (Entity List)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Liability of senior managers
- According to BIS, the responsible compliance staff and senior executives from sales and production are no longer employed.
- Published
- 12 Feb 2026
Original amount 252,500,300 USD, converted at the ECB reference rate of 11 Feb 2026.
- BIS: Applied Materials to Pay $252 Million Penalty for Illegally Exporting Semiconductor Manufacturing Equipment (12.02.2026) Press release of an authority
- BIS Order Relating to Applied Materials, Inc. and Applied Materials Korea (11.02.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Jan 2026 Exyte Management GmbHExyte: 1.5 million USD – Chinese subsidiary arranged US goods for listed chipmaker SMIC €1.28m
The Shanghai company of the Stuttgart-based Exyte group caused around 884 US items (flowmeters, pressure transmitters, controllers) worth around 2.85 million USD to be delivered by Chinese suppliers to SMIC Beijing, which is on the Entity List (the US export control list of restricted parties), on 13 occasions in 2021/22. According to the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce), the compliance programme did not recognise that in-country transfers within China also require a licence; Exyte voluntarily disclosed the transactions and admitted them.
Screen end customers against the Entity List in foreign subsidiaries too, even for local purchases – US export law also covers transfers of US goods within China.
Entity List screening also for domestic deliveries abroad
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, 15 C.F.R. § 764.2(b), § 744.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Construction and real estate
- Culpability
- negligent
- Mitigating circumstances
- Voluntary self-disclosure, own investigation with external lawyers and investment in the compliance programme.
- Published
- 7 Jan 2026
Original amount 1,500,000 USD, converted at the ECB reference rate of 7 Jan 2026.
- BIS Imposes Administrative Penalty on Exyte Management GmbH Press release of an authority
- Order Relating to Exyte Management GmbH (7. Januar 2026) mit Settlement Agreement Decision of an authority
Checked against the official source on 28 Sep 2026 · Direct link
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1 Dec 2025 British exporter pays 620,515 GBP for unlicensed exports of military goods €706,898
In September 2025, an unnamed British exporter paid a compound settlement of 620,515.04 GBP to HM Revenue & Customs (HMRC) for unlicensed exports of military goods. HMRC offers such settlements only for unintentional breaches or weaknesses in internal controls and following voluntary disclosure (date = publication).
Weaknesses in internal export control become expensive even without intent – disclosing breaches early can avoid prosecution.
Classification of goods and licensing requirements for military goods
- Authority / court
- HM Revenue & Customs (HMRC) / Export Control Joint Unit
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Control Order 2008
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Culpability
- negligent
- Mitigating circumstances
- Voluntary disclosure (prerequisite for the compound settlement)
- Published
- 1 Dec 2025
Original amount 620,515.04 GBP, converted at the ECB reference rate of 1 Dec 2025.
- NTE 2025/31: UK exporter pays compound settlement for breaches of export controls Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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28 Jul 2025 Cadence Design Systems Inc.Cadence pleads guilty: chip design software for Chinese military university €120.1m
From 2015 to 2021, the San José provider of chip design software supplied hardware, software and semiconductor IP at least 59 times to the National University of Defense Technology (NUDT), a military university on the Entity List, disguised under the alias Central South CAD Center. Cadence pleaded guilty before the US Department of Justice to conspiracy to commit export control violations; criminal penalties of almost 118 million USD and civil penalties of more than 95 million USD imposed by the Bureau of Industry and Security (BIS) result, after crediting, in a net total of more than 140 million USD.
Include cover names and known aliases of listed customers in screening; sales and compliance must escalate indications of military end users.
Recognising aliases and cover names of listed customers
- Authority / court
- U.S. Department of Justice; Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations (Entity List); ECRA; Verschwörung zu Exportkontrollverstößen
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Telecoms, IT and software
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 28 Jul 2025
Original amount 140,000,000 USD, converted at the ECB reference rate of 28 Jul 2025.
- DOJ: Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting to Military University in China (28.07.2025) Press release of an authority
- BIS: Cadence Design Systems to Pay $95 Million Penalty to BIS for Unauthorized Exports to Chinese Entities (28.07.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Apr 2025 Britisches Exportunternehmen, Militärgüter (anonymisiert)UK exporter pays £3.23m for unlicensed exports of military goods €3.74m
A UK company not named by HMRC paid a compound settlement of £3,231,762.40 in February 2025 in lieu of prosecution over the alleged export of military goods without the licence required under the Export Control Order 2008. HMRC set out the facts in these terms. It was the largest of three settlements totalling close to £3.7 million that HMRC concluded between January and March 2025; no sanctions offences were involved.
Before every export, check whether the goods are military-listed and obtain the appropriate licence.
Classification of goods and licensing requirements for military goods
- Authority / court
- HM Revenue & Customs (HMRC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Control Order 2008; Customs and Excise Management Act 1979
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Published
- 9 Apr 2025
Original amount 3,231,762.4 GBP, converted at the ECB reference rate of 9 Apr 2025.
Checked against the official source on 3 Oct 2026 · Direct link
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1 Nov 2024 GlobalFoundries U.S. Inc.; GlobalFoundries U.S. 2 LLCBIS: USD 500,000 against GlobalFoundries for shipments to a listed company €459,348
As part of a settlement, the Bureau of Industry and Security imposed a civil penalty of USD 500,000 on GlobalFoundries U.S. Inc. and its subsidiary GlobalFoundries U.S. 2 LLC. Between February 2021 and October 2022 the company sent semiconductor wafers worth around USD 17.1 million in 74 shipments without authorisation to SJ Semiconductor, a company on the Entity List; owing to a data entry error, the service provider designated by the customer had not been screened in the screening system. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Service providers designated by customers, such as test and assembly contractors, must also be screened against sanctions and Entity Lists.
Sanctions list screening of all parties to a transaction
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- 15 C.F.R. § 764.2(a) (Export Administration Regulations)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Mitigating circumstances
- According to BIS, voluntary self-disclosure, cooperation and remedial measures led to a significant reduction of the penalty.
- Published
- 1 Nov 2024
Original amount 500,000 USD, converted at the ECB reference rate of 1 Nov 2024.
Checked against the official source on 3 Oct 2026 · Direct link
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29 Aug 2024 a US defence groupDDTC: USD 200 million against US defence group for ITAR violations €180.4m
The US State Department's Directorate of Defense Trade Controls settled with a US defence group for a civil penalty of USD 200 million for violations of the Arms Export Control Act and the ITAR. The allegations concerned unauthorised exports of defence articles resulting from flawed jurisdiction and classification decisions, further unauthorised exports, including of classified defence articles, hand-carried exports by employees to countries proscribed under ITAR § 126.1, and breaches of authorisation provisos. USD 100 million is suspended provided the group spends it on approved compliance measures; USD 100 million is payable in three instalments.
Correct jurisdiction and classification decisions are the basis of every export authorisation; errors there multiply across the portfolio.
Export control for defence articles: classification, hand-carry and authorisation provisos
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Mitigating circumstances
- The allegations are based on facts that the group itself disclosed to the DDTC.
Original amount 200,000,000 USD, converted at the ECB reference rate of 29 Aug 2024.
Checked against the official source on 8 Oct 2026 · Company name anonymised since 29 Aug 2026 · Direct link
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28 Feb 2024 a US aerospace groupDDTC: USD 51 million against US aerospace group for unauthorised technical data transfers €47.2m
The DDTC settled with a US aerospace group for a civil penalty of USD 51 million for ITAR violations: unauthorised exports and retransfers of technical data to foreign-person employees and contractors, unauthorised exports to the People's Republic of China as a proscribed country, and breaches of authorisation provisos. USD 24 million is suspended for approved compliance measures; USD 27 million is payable in three instalments.
Access by foreign-person employees to controlled technical data is an export and requires authorisation and technical access controls.
Deemed exports: foreign-person employees' access to controlled technical data
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Mitigating circumstances
- The allegations are based on facts that the group itself disclosed to the DDTC.
Original amount 51,000,000 USD, converted at the ECB reference rate of 28 Feb 2024.
Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Feb 2026 · Direct link
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19 Apr 2023 a US hard disk drive manufacturer and its entity in SingaporeBIS: USD 300 million against US hard drive maker for shipments to Chinese group €274.4m
The Bureau of Industry and Security imposed a civil penalty of USD 300 million on a US hard disk drive manufacturer and its international headquarters in Singapore, payable in 20 quarterly instalments of USD 15 million. Between August 2020 and September 2021, the manufacturer supplied around 7.4 million foreign-produced hard disk drives worth about USD 1.1 billion on 429 occasions without authorisation to entities of a Chinese telecommunications group on the Entity List, although these were subject to the foreign direct product rule. The order also provides for three audits of the export compliance programme and a denial order suspended for five years.
The foreign direct product rule also covers products manufactured abroad – supply chains must be checked for US technology used in production.
Foreign direct product rule and supplies to companies on the Entity List
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- 15 C.F.R. § 764.2(a) (Export Administration Regulations); Export Control Reform Act of 2018 (50 U.S.C. §§ 4801–4852)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Published
- 19 Apr 2023
Original amount 300,000,000 USD, converted at the ECB reference rate of 19 Apr 2023.
Checked against the official source on 8 Oct 2026 · Company name anonymised since 19 Apr 2025 · Direct link
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24 Feb 2023 a US manufacturer of 3D printersDDTC: USD 20 million against US 3D printer manufacturer for transfers of technical data €18.9m
The DDTC settled with a US manufacturer of 3D printers for a civil penalty of USD 20 million for unauthorised exports and retransfers of technical data to various countries, including a country proscribed under the ITAR, and for deficient ITAR records. USD 10 million is suspended for approved compliance measures and USD 10 million is payable in three instalments. A few days later the Bureau of Industry and Security imposed a separate penalty for violations of the Export Administration Regulations.
Anyone sharing technical data digitally with sites and partners must check and document export control before each transfer.
Transfers of technical data and ITAR record-keeping duties
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Mitigating circumstances
- The allegations are based on facts that the company itself disclosed to the DDTC.
Original amount 20,000,000 USD, converted at the ECB reference rate of 24 Feb 2023.
Checked against the official source on 8 Oct 2026 · Company name anonymised since 24 Feb 2025 · Direct link