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U.S. Bureau of Industry and Security (BIS)

Call 305-456-3830 or email info@diaztradelaw.com.

Bosch Agrees to Pay $36 Million Penalty to BIS for Unauthorized Shipments to Huawei 

Robert Bosch GmbH (Bosch), the German multinational engineering and technology company, has agreed to pay a $36,184,680 penalty to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for exporting controlled items to Huawei Technologies Co. and its affiliates without the required U.S. government authorization. 

What Happened 

Between September 2020 and September 2024, Bosch exported approximately $72.4 million worth of Micro-Electro-Mechanical Systems (MEMS) sensor products and automotive software from abroad to Huawei and its affiliates. The exported items were subject to the Export Administration Regulations (EAR) under the Foreign Direct Product Rule, a rule that extends U.S. export controls to certain foreign-produced items that incorporate U.S. technology or are manufactured using U.S. equipment. Because Huawei and its affiliates are listed on BIS’s Entity List, any shipment of items subject to the EAR requires a license from BIS. No such license or authorization was obtained. 

The MEMS sensors at issue are widely used in consumer products, including smartphones, wearable technology, and automobiles. 

The Penalty 

In addition to the $36 million BIS civil penalty, Bosch separately agreed with the Department of Justice to disgorge profits from the transactions, with an actual payment of approximately $3.6 million. BIS suspended approximately $3.6 million of its penalty as credit for the disgorgement, bringing Bosch’s total financial exposure to roughly $39.8 million. 

Bosch filed a Voluntary Self-Disclosure with […]

By |2026-06-18T12:00:26-04:00June 18, 2026|EAR, Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS)|0 Comments
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You’ve Been Asked to Boycott – What to Know Before You Self‑Disclose

Companies engaged in international trade occasionally encounter requests that raise red flags under the U.S. anti‑boycott regulations. Whether the request appears in a tender document, a purchase order, a letter of credit, oral agreement, verbal request to furnish particular information, or a casual email, the moment you spot boycott‑related language, and become aware that your organization has complied with the request, the clock starts ticking to self-disclose to the Office of Antiboycott Compliance (OAC)

By |2026-03-19T16:57:15-04:00March 13, 2026|U.S. Bureau of Industry and Security (BIS)|0 Comments
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2025 and Beyond: BIS Updates Boycott Requester List

On April 3, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an updated list of foreign companies that have made boycott-related requests, including requests to comply with the Arab League boycott of Israel. In addition to removing 18 entities who have certified that they have ceased making such prohibited requests, BIS added 30 parties to its list (outlined below). Majority of the newly listed entities are domiciled in Malaysia, which aligns with the country’s foreign policy position that it refuses diplomatic and economic relations with Israel. While companies generally want to comply with the laws of every jurisdiction in which they operate, it is important to understand the risks of non-compliance with OAC rules.  

As recommended by BIS, U.S. companies are encouraged to diligently review transaction documents from all sources, especially those involving these listed parties, to identify possible boycott-related language and to determine whether their recipients have a reporting requirement to BIS.   

If you are unsure whether the language of your contracts must be reported to the OAC or concerned about doing business in jurisdictions where listed entities have been identified, contact Diaz Trade Law today at info@diaztradelaw.com or 305-456-3830.  

Want more information on OAC compliance? Read more here. 

By |2026-03-27T15:41:10-04:00March 7, 2026|U.S. Bureau of Industry and Security (BIS)|0 Comments
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ICYMI: Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria

On November 7, 2025, the Office of Foreign Assets Control (OFAC), alongside the U.S. Department of State and the U.S. Department of Commerce, issued a Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria. 

The Advisory follows President Trump’s Executive Order on June 30, 2025, formally removing U.S. sanctions on Syria and directing agencies to take additional measures to encourage U.S. private sector and foreign partner reengagement in Syria.

New Opportunities & Remaining Restrictions

The Advisory outlines what business with Syria is now permissible as well as what restrictions remain.

Permissible Business:

  • The United States no longer imposes comprehensive sanctions on Syria. 
  • The Caesar Act is suspended, except for sanctionable transactions with Russia and Iran.
  • The transfer of most basic civilian use U.S.-origin goods, as well as software and technology, to or within Syria is permitted without a license. 

Remaining Restrictions:

  • Sanctions remain on “the worst of the worst:” Bashar al-Assad and his associates, human rights abusers, drug traffickers, and other destabilizing regional actors.
  • The U.S. Government continues to review Syria’s State Sponsor of Terrorism (SST) designation. 
  • Most Commerce Control List items going to Syria still require a U.S. export license.

What Exporters Should Do

The removal of Syria sanctions and the easing of […]

By |2025-11-24T11:18:20-05:00November 24, 2025|Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC), U.S. Department of State (DOS), U.S. Office of Foreign Assets Control (OFAC)|0 Comments
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Tariff Updates: Heavy Trucks, Timber & Lumber, Vessel Fees

Over the past several weeks, there has been a flurry of tariff updates affecting importers across multiple industries. From tariffs on heavy-duty vehicles and timber to 232 exclusions and vessel fees, the trade landscape is moving fast, and staying compliant is more challenging than ever. To help you keep up, we’ve summarized recent key tariff developments you need to know. For a full list of tariffs and trade deals, visit our tracker here.

Heavy-Duty Vehicles and Vehicle Parts

On September 25, 2025, President Trump, via Truth Social, announced his intention to impose a 25% tariff on heavy trucks. On October 17, 2025, he issued a Presidential Proclamation formalizing and clarifying these tariffs. The proclamation imposes a 25% tariff on imports of medium- and heavy-duty trucks and truck parts. This includes Class 3 to Class 8 vehicles, like large pick-up trucks, moving trucks, cargo trucks, dump trucks, and tractors for eighteen-wheelers. 

The Proclamation also imposes a 10% tariff on imports of buses, including school buses, transit buses, and motor coaches. The tariffs are set to take effect on November 1, 2025.

President Trump is imposing the new tariffs under section 232 of the Trade Expansion Act of 1962, citing national security concerns.

If medium and heavy-duty vehicles qualify for USMCA treatment, the importer may submit documentation to identify the amount of U.S. content, and, after the Department of Commerce’s […]

By |2025-10-24T10:50:49-04:00October 24, 2025|Enforcement, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC)|0 Comments
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