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Bosch to pay $36 million penalty for unlicensed shipments to Huawei

Robert Bosch GmbH has agreed to pay a USD 36 million penalty to the US Bureau of Industry and Security after shipping MEMS sensor products and software to Huawei and its affiliates without the required export licence. The shipments took place between September 2020 and September 2024.

The products – MEMS sensors and related software for cell phones – were subject to US export controls under the Foreign Direct Product Rule, which extends American export regulations to foreign-made items that incorporate certain US technology. Huawei has been on the US Entity List since 2019, meaning exports to the company require explicit government authorisation. 

Bosch shipped approximately USD 72 million worth of goods to Huawei and its affiliates over the four-year period without that authorisation, according to a press release from BIS.

Bosch filed a voluntary self-disclosure and cooperated with the investigation, factors that typically result in reduced penalties under BIS enforcement practice. Separately, Bosch agreed with the Department of Justice to disgorge profits, with an actual payment of approximately USD 3.6 million. BIS credited that amount against its own penalty, reducing the fine by the same amount.

"This settlement agreement underscores BIS's commitment to strong enforcement as well as incentivising voluntary disclosures of past violations," said David Peters, Assistant Secretary of Commerce for Export Enforcement.


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