The OverRuled: Sanctions Module has been updated with the following actions:
- 12 Feb 2026 - IMG Academy, LLC - USD $1,720,000
Between 2019 and 2025, IMG Academy, LLC ("IMG Academy"), a school and athletic training facility headquartered in Bradenton, Florida, dealt in the property or interests in property of two Specially Designated Nationals (SDNs) sanctioned for their ties to a sanctioned Mexico-based drug cartel. Specifically, IMG Academy entered into yearly tuition agreements with the SDNs and received and processed payments pursuant to those agreements.
The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 11 Feb 2026 - Applied Materials, Inc.; Applied Materials Korea - Denial Order; USD $252,500,300
BIS issued an Order approving a settlement between BIS and Applied Materials, Inc. and Applied Materials Korea (the “Respondents”) in connection with violations of 15 C.F.R. §§ 764.2(a) and 764.2(c). Specifically, on 54 occasions between March 23, 2021 and June 3, 2022, Applied Materials, Inc. caused the reexport of module systems of ion implanters from Applied Materials Korea to Semiconductor Manufacturing International Corporation (“SMIC”) or its subsidiaries that were listed on the BIS Entity List. On November 8, 2020, Applied Materials, Inc. attempted to cause the reexport of ion implanting equipment of one ion implanter to a SMIC subsidiary after receiving an is-informed letter from BIS that reexport of such items would require a license. On July 18, 2022, Applied Materials, Inc. attempted to cause the reexport of ion implanting equipment of one ion implanter to a SMIC subsidiary that was listed on the BIS Entity List. The total value of the equipment subject to the violations was approximately $126,250,150 and all equipment was classified under ECCN 3B991. As part of the settlement and Order, Respondents were assessed a civil penalty of $252,500,300. Additionally, BIS issued a three-year suspended Denial Order against Respondents.
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