The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 28 Jul 2025 - Cadence Design Systems, Inc. - No Denial Order; USD $95,312,000
BIS issued an Order approving a Settlement Agreement between BIS and Cadence Design Systems, Inc. (the “Respondent”) in connection with violations of 15 C.F.R. §§ 764.2(a), 764.2(c) and 764.2(e). Specifically, on 56 occasions between approximately September 2015 and September 2020, Cadence Design Systems Management (Shanghai) Co., Ltd. (“Cadence China”), a subsidiary of Respondent located in China through which Respondent sells products and services to customers in China, sold or loaned items subject to the EAR to Central South CAD Center (“CSCC”), an alias of Entity List party National University of Defense Technology (“NUDT”), in China without the required license or other authorization from BIS. The items were Electronic Design Automation ("EDA") hardware and software and semiconductor design technology, in particular intellectual property, controlled under ECCNs 3B991.b.2.c, 3D991, 3E991, or designated EAR99. Additionally, between approximately November 1, 2020 and February 1, 2021, Respondent transferred CSCC’s software and technology to Phytium Technology Co. Ltd, also known as Tianjin Phytium Information Technology, Phytium or Feiteng (“Phytium”), also in China, with reason to know that the hardware had previously been exported to CSCC without the required license or other authorization from BIS. Phytium was later designated on the Entity List on April 8, 2021. Further, between September 2016 and December 2021, due to certain system-level gaps, three of Respondent’s customers in China and Russia were able to download EDA software subject to the EAR after their designation to the Entity List. As part of the Settlement Agreement and Order, Respondent was assessed a civil penalty of $95,312,000. This BIS enforcement action was concurrent with a Plea Agreement between the Respondent and the Department of Justice, which includes a forfeiture in the amount of $45,305,317.41.
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