The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 07 Jan 2026 - Exyte Management GmbH - No Denial Order; USD $1,500,000
BIS issued an Order approving a settlement between BIS and Exyte Management GmbH (the “Respondent”) in connection with violations of 15 C.F.R. § 764.2(b). On 13 occasions between on or about March 8, 2021, through on or about March 24, 2022, Exyte Shanghai Ltd., (“Exyte China”), a member of the Respondent group located in China, aided the in-country transfer of approximately 884 EAR99 items to Semiconductor Manufacturing International (Beijing) Corporation, a party on the BIS Entity List, without the required license or other authorization from BIS. The EAR99 items included flowmeters, pressure transmitters, logic controllers, and voltage sag protectors, collectively valued at approximately $2,850,030. BIS determined that Exyte China facilitated the transfers at issue, without identifying the need for a license, because of Respondent’s inadequate corporate compliance controls regarding the applicability of U.S. export controls over in-country transfers by local Chinese suppliers. As part of the settlement and Order, Respondent was assessed a civil penalty of $1,500,000.
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