Finding the Perfect Export Enforcement Case (Part 1)

Finding the Perfect Export Enforcement Case (Part 1)


Are you looking for the PERFECT export enforcement case to highlight in your export control training?  You know…the export violation that demonstrates U.S. export controls regulations really do touch your industry, your research field, your size company, and your personnel.  It’s not just about the one individual who willfully did the wrong thing. OFAC violations, ITAR violations, and EAR violations inadvertently occur at organizations of all sizes.  (Of course, the really big ones like ZTE and Huawei are always interesting to discuss, too.)  And it’s not just about any single set of export controls regulations.  EAR compliance, ITAR compliance, and OFAC compliance all matter.

Well, we’ve done the homework for you and have consolidated an organized list of export enforcement cases (or near misses and/or dropped charges) that you can pull from.   Now you can more easily paint that picture you’ve been aiming to create in your export control compliance training.

In some cases, charges have been filed. In other cases, export penalties have been imposed as part of a settlement, or the case was dropped due to changing export regulations.  The export violation (or suspected violation) also ranges from exporting an EAR99 item to a Restricted Party to exporting an item controlled under a specific ECCN classification.  Sometimes the wrong export classification was used. In all cases, the proper authorization (e.g., export license from BIS) was not obtained in advance, leading to export penalties or charges that may lead to export fines.



Huawei  (Interesting read: Huawei’s export control compliance statement)


MHz Electronics

Johnny Paul Tourino – computer servers

Aeroflex / Metelics / Cobham Holdings – switch limiters

Shai Gear / Spider Camera

Multiwire Laboratories – camera detectors to university on BIS Entity List

Yi-Chi Shih and Kiet Ahn Mai – monolithic microwave integrated circuits (MMICs)

Intersil Corporation – circuits

Advanced Materials and Chemicals

Fuyi Sun – carbon Fiber

Richard Phillips – carbon Fiber

Ming Suan Zhang – carbon Fiber

Global Metallurgy, LLC – specialty metals

Cerac Inc. – specialty inorganic materials

Chemguard, Inc. – anti-boycott regulations


Dr. Thomas Butler (Texas Tech University) – highlighted in the BIS Don’t Let This Happen to You

Professor Reese Roth – plasma technology for UAV (drone)

University of Massachusetts Lowell – antenna and cables

University Professor – dropped case

Medical, Healthcare, and Bioscience

Medical researcher – dropped case about MRI coil

Dentsply Sirona Inc. – dental equipment and supplies

Alcon Laboratories / Pharmaceuticals – surgical and pharmaceutical products

United Medical Instruments Inc. – medical imaging equipment

HyperBranch Medical Technology

GE Bioscience (Wave Biotech, LLC) – bioreactor kits

Analytical Equipment

Muhammad Ismail and Kamran Kahn – spectrometer (and film for composite fabrication)

Federal Express – electron microscope components

Other Equipment

Hetran Inc. – horizontal lathe

Sihai Cheng – pressure transducers

See Kee Chin – accelerometer

Qiang Hu (MKS Instruments, Inc.) –  pressure transducers

Emerging Technologies:  Drones, UAVs, and 3D Printing

Hui Sheng Shen and Huan Ling Chang – drones

Cody Wilson – 3D Printing

Many of the above export enforcement cases involve unintentional violations.  These costly penalties could have been avoided with a careful export license determination – followed by the proper export license application.  Watch out for Part 2 in a future blog where we’ll cover more industries, including Oil and Gas, Aerospace, Space, and Aviation.

Not sure how to craft a compelling message in your export compliance training?  We can help develop customized export compliance training. Contact us here.

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