On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR)
Enforcement
BIS Fines Exyte $1.5 Million for Unlicensed Transfers to China’s SMIC
By Jeremy Iloulian & Nate Young on
On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $1.5 million civil penalty on Exyte Management GmbH (“Exyte”), a Germany- headquartered engineering and procurement company, after its Shanghai affiliate Exyte Shanghai Ltd., (“Exyte China”) admitted to illegally causing the transfer of approximately $2.8 million in EAR-subject semiconductor…
OFAC Publishes Guidance on Extended Statute of Limitations
By Caroline Brown, Dj Wolff & Jackie Schaeffer on
Posted in Office of Foreign Assets Control (OFAC)
On July 22, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance (“Guidance”) on how it will implement the new authority it was granted in the April 24, 2024 National Security Supplemental (“the Act”). The Act extended the statute of limitations for civil, criminal, and forfeiture violations of sanctions…