The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 16 Jun 2026 - Robert Bosch GmbH - No Denial Order; USD $36,184,680
BIS issued an Order approving a settlement between BIS and Robert Bosch GmbH (the “Respondent”) in connection with 109 violations of 15 C.F.R. § 764.2(a). Specifically, on 109 occasions between September 16, 2020, and September 26, 2024, Respondent, through its German subsidiaries Sensortec GmbH and ETAS GmbH, sold, transferred, and/or exported from abroad Micro-Electro-Mechanical Systems sensor products and CycurHSM automotive firmware software to Huawei Technologies Co., Ltd. and its affiliates on the Entity List. Respondent did so without a required license or other authorization from BIS. The products were classified as EAR99 but were subject to the EAR under the Foreign Direct Product Rule. The items were valued at approximately $72,369,361. As part of the settlement and Order, Respondent was assessed a civil penalty of $36,184,680, with $3,601,029 suspended. The Respondent entered into a parallel agreement with the Department of Justice (“DOJ”) in which DOJ declined to pursue criminal charges related to this matter on the condition that Respondent pay a disgorgement of $11,430,098, which represented Respondent’s profits from the violations. DOJ credited $7,829,069 of the disgorgement amount against the BIS penalty amount.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 17 Jun 2026 (UK):
The Office of Financial Sanctions Implementation ("OFSI") announced that, in accordance with section 146 of the Policing and Crime Act 2017, a monetary penalty of £1,000,920.59 was imposed on May 26, 2026 against Sabre Global Technologies Limited ("SGTL"), a UK-registered company that provides the travel industry with access to travel content, earning booking fees in exchange.
The penalty was imposed against SGTL for breaching UK financial sanctions prohibitions by making funds available for the benefit of a designated person ("DP") (regulation 13), making economic resources available to a DP (regulation 14), and circumventing UK sanctions prohibitions (regulation 19) under the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The enforcement action is notable because it represents OFSI's largest civil monetary penalty under the Russia Regulations, and the penalty is also the first issued by OFSI for a circumvention offense.
- 15 Jun 2026 (EU):
The European Commission (the "Commission") updated its Russia sanctions FAQs in respect of the import ban on refined petroleum products obtained from Russian crude oil, pursuant to Article 3ma of Council Regulation (EU) No. 833/2014. The Commission's update clarifies: (i) documentary evidence requirements for volume-based control checks to certify the non-Russian origin of crude oil for petroleum products being imported to the EU; and (ii) independent verification requirements for such checks.
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