The Bureau of Industry and Security (BIS) recently reached a settlement imposing a $252 million penalty against a U.S. company for alleged export control violations stemming from conflating U.S. customs and export regulations.
According to the settlement, the company appears to have pursued its approach after incorrectly concluding that if an item is “substantially transformed” in a foreign country, it would no longer be subject to U.S. export control requirements under the Export Administration Regulations (EAR).