World ECR | BIS: 15 Export Control and Sanctions Offenses

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) filed 15 criminal cases in 2024 alleging sanctions and export control violations, conspiracy to smuggle, and other crimes related to the transfer of sensitive technology to China, Russia, and the United States. According to the agency’s annual review released on January 2, Iran strikes through disruptive technology strike forces.

The multi-agency strike force expanded from 14 to 17 locations last year, with new cells in Texas, Georgia and North Carolina targeting multiple illicit Russian procurement networks. Key actions include obtaining “a guilty plea from a defendant who played a key role in the export of sensitive electronic components to Russia for the development of nuclear and hypersonic weapons” and the prosecution and extradition of “a Russian-German citizen from Cyprus” for Russian defense The base purchases a large number of microelectronic products.

Along with the Department of Justice (DOJ) and other enforcement partners, BIS has also imposed significant financial penalties, including $3.3 million against a California company for “exporting transistors and related products, including Common High Priority List (CHPL) items.” Civil Penalties, to Russia” and a reduced $180,000 fine against a New York company for exporting “solder used in electronics manufacturing” to Russia.

Actions against China include “a Chinese national pleading guilty to illegally exporting semiconductor manufacturing machinery to a Chinese entity listed company.” BIS also imposed a $5.8 million administrative penalty on TE Connectivity for voluntarily self-disclosing unauthorized exports to parties associated with China’s military electronics programs.

The agency has expanded its international cooperation efforts, establishing disruptive technology protection networks with Japan and South Korea, and signed bilateral agreements with the governments of Australia, Japan, South Korea and Switzerland “to promote law enforcement cooperation and information sharing.”

BIS adds addresses to Entity List for the first time – “16 addresses in Hong Kong and Turkey hosting hundreds of shell companies that diverted more than $130 million in high-priority projects to Russia.” The agency also added 22 entities The list was added to the list of entities that “acquire or attempt to acquire items originating in the United States to enhance China’s quantum capabilities.”

Other significant enforcement actions include the seizure of a $13 million Dassault Falcon 900EX aircraft owned by Venezuelan President Nicolás Maduro and the confiscation of a Boeing 747 freighter previously owned by sanctioned Iranian airline Mahan Air.

The agency is beefing up its enforcement programs by hiring “BIS’s first corporate enforcement director to serve as the primary liaison between BIS agents, BIS enforcement attorneys and DOJ prosecutors to facilitate the resolution of corporate investigations.” It also established a commercial screening system that “automatically screens 100% of export license applications for foreign entities based on intelligence information, replacing a completely manual process.”