LinkedInFacebookTwitterInstagramYouTubeEmailPhone

BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations 

On October 2, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $2 million administrative settlement with Massachusetts-based Lambda Research Corporation involving 66 alleged violations of the Export Administration Regulations (EAR). The case involved exports of optical and illumination design software, automatic software updates, and transactions with parties on the Entity List and Unverified List. 

Key Takeaways 

  • EAR99 does not mean unrestricted. Even software classified as EAR99 may require an export license when the recipient is on the BIS Entity List. 
  • Automatic software updates can constitute exports. BIS charged Lambda with violations involving software updates transmitted to restricted parties after their addition to the Entity List. 
  • Restricted-party screening must be ongoing. A customer who was not restricted when a transaction began may become subject to licensing requirements later. 
  • Distributors do not eliminate export compliance obligations. Exporters must evaluate the actual end users of their products, including transactions conducted through intermediaries. 
  • The Unverified List creates additional compliance requirements. Certain transactions involving Unverified List parties require a UVL statement even when an export license is not otherwise required. 
  • Informal compliance efforts are insufficient. BIS cited Lambda’s lack of written export compliance procedures, employee training, and designated compliance personnel. 
  • Voluntary self-disclosure does not eliminate penalties. […]
By |2026-10-09T11:34:59-04:00October 9, 2026|EAR, Enforcement, Export, Penalty, U.S. Bureau of Industry and Security (BIS)|0 Comments
Read More

BIS FY2025 Annual Report Signals Major Increase in Export Enforcement 

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released its Fiscal Year 2025 Annual Report to Congress, providing a detailed look at the agency’s export control, licensing, and enforcement activity.  

Key Takeaways 

  • BIS reports an 18-fold increase in penalties, from approximately $16 million in calendar year 2024 to approximately $324 million in 2025. 
  • BIS completed 53 administrative enforcement actions, resulting in more than $108 million in civil penalties during FY2025. 
  • BIS enforcement activity included 455 warning letters, 705 detentions, 232 seizures, and 29 denial orders. 
  • BIS investigations resulted in 65 criminal convictions of individuals and companies during FY2025. 
  • BIS completed 1,840 end-use checks across 73 countries, demonstrating the agency’s ability to scrutinize transactions even after goods leave the United States. 
  • BIS added 142 entities to the Entity List, including parties associated with advanced computing, quantum technology, hypersonic weapons programs, and Iranian drone procurement. 
  • Licensing for Entity List parties has become significantly more restrictive: BIS reports granting only 16 new licenses to Entity List companies during Q2–Q4 2025. 
  • Exporters should reassess restricted-party screening, end-user and end-use diligence, product classification, licensing procedures, recordkeeping, and escalation protocols in light of […]
By |2026-09-11T14:55:38-04:00September 11, 2026|Best Practices, EAR, Enforcement, Export, U.S. Bureau of Industry and Security (BIS)|Comments Off on BIS FY2025 Annual Report Signals Major Increase in Export Enforcement 
Read More

ICYMI: Technology Company Pleads Guilty to Export Control Violations, Agrees to $140M Fine

The U.S. Attorney’s Office for the Northern District of California and the Counterintelligence and Export Control Section (CES) of the Department of Justice’s (DoJ) National Security Division announced that Cadence Design Systems, Inc. of San Jose, California, agreed to plead guilty to resolve criminal violations of export controls. 

As part of the plea agreement, Cadence will pay criminal penalties of nearly $118 million. 

In addition to the charges, the Department of Commerce’s Bureau of Industry and Security (BIS) also announced the resolution of a civil enforcement action against the company in which Cadence agreed to pay over $95 million in civil penalties. 

The DoJ and BIS have coordinated the resolution of the parallel investigation, and each agreed to a partial credit against their fine for payments made to satisfy the other agency’s fine. Under the coordinated agreement, Cadence will pay criminal and civil penalties of more than $140 million.

Cadence committed criminal violations of the export control laws by selling hardware, software, and semiconductor design intellectual property to the National University of Defense Technology (NUDT) in China. NUDT was added to the Department of Commerce’s Entity List in February 2015. The university was involved in the development of supercomputers with applications for military and nuclear explosive simulations. 

Cadence and its Chinese subsidiary engaged in a conspiracy to commit export control violations by exporting this technology to NUDT without obtaining the requisite licenses from […]

By |2025-08-07T11:02:35-04:00August 7, 2025|EAR, Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Justice (DOJ)|Comments Off on ICYMI: Technology Company Pleads Guilty to Export Control Violations, Agrees to $140M Fine
Read More

ICYMI: BIS Initiates 232 Investigations of UAS and Polysilicon Imports

On July 15, 2025, the Bureau of Industry and Security announced Section 232 National Security Investigations of: (i) Unmanned Aircraft Systems (UAS) and their parts/components, and (ii) polysilicon and related derivatives.

The Federal register notices are available here (UAS) and here (polysilicon).

BIS is specifically interested in the following information:

  1. The current and projected demand for these products and the extent to which domestic production can meet this demand
  2. The role of foreign supply chains, particularly of major exporters, in meeting United States demand 
  3. The concentration of U.S. imports from a small number of suppliers and the associated risks
  4. The impact of foreign government subsidies and predatory trade practices 
  5. The economic impact of artificially suppressed prices due to foreign unfair trade practices and state-sponsored overproduction
  6. The potential for export restrictions by foreign nations
  7. The feasibility of increasing domestic capacity to reduce import reliance
  8. The impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security

The deadline to submit comments is August 6, 2025.

The investigations could result in new trade restrictions, including tariffs. If you import products covered under these investigations, make your […]

By |2025-07-22T07:45:54-04:00July 22, 2025|Enforcement, Export, Import, International Trade, Tariffs, Trade Policy, U.S. Bureau of Industry and Security (BIS)|Comments Off on ICYMI: BIS Initiates 232 Investigations of UAS and Polysilicon Imports
Read More
Go to Top