BIS Fines Teledyne FLIR $1M for Unlicensed China Exports

Crowell & Moring Trade Blog

Filed February 26th, 2026

Detected March 2nd, 2026

Summary

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) settled with Teledyne FLIR for $1,000,000 over alleged violations of the Export Administration Regulations (EAR). The violations involved unlicensed exports of thermal imaging cameras to China and miscalculations under the de minimis rule.

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What changed

BIS has imposed a $1,000,000 civil penalty on Teledyne FLIR LLC and its affiliates to resolve allegations of violating the Export Administration Regulations (EAR). The settlement addresses 19 alleged violations between 2017 and 2024, including causing unlicensed exports of thermal imaging cameras to China based on incorrect de minimis calculations, an evasion scheme involving a Chinese drone manufacturer, failure to keep required records, and unlicensed exports to an Entity List address. The violations involved export control classification numbers ECCN 6A003 and 6A993.a.

This enforcement action highlights the complexities of de minimis analysis and the need for accurate fair market value assessments to avoid evasion allegations. Companies must also implement robust screening processes for address-only Entity List entries and maintain disciplined recordkeeping for all license requirements. Failure to comply with these EAR provisions can result in significant civil penalties and reputational damage.

What to do next

Review de minimis calculation methodologies for accuracy and fair market value adherence.
Enhance screening processes to include address-level controls for Entity List entries.
Strengthen recordkeeping practices related to export authorizations and license conditions.

Penalties

$1,000,000 civil penalty

Source document (simplified)

On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations of the Export Administration Regulations (“EAR”).

According to BIS, Teledyne FLIR voluntarily self-disclosed 19 alleged violations between 2017 and 2024 tied to exports, reexports, and related conduct involving thermal imaging cameras under export control classification numbers (“ECCN”) 6A003 and 6A993.a. The penalties broke into four types of violations:

Causation: BIS alleged that Teledyne FLIR caused nine exports from abroad of ECCN 6A003 thermal imaging cameras from a Swedish affiliate to China without required BIS authorization, based in part on incorrect calculations under the EAR’s de minimis rule in 15 C.F.R. Part 734.
Evasion: BIS alleged an evasion-related fact pattern involving a 2018 collaboration with a Chinese drone manufacturer concerning the Zenmuse XT2, a project involving the integration of a FLIR camera for use with civilian drones. This evasion scheme consisted of a pricing structure that BIS alleged was designed to keep U.S.-controlled content below the de minimis threshold and did not reflect the fair market value of the items.
Failure to Keep Records: BIS alleged failures to comply with license-condition recordkeeping requirements for certain demonstrations by the Shanghai affiliate.
Exports to Entity List Address: BIS alleged eight unlicensed exports of ECCN 6A993.a thermal cameras to company included on the Entity List for being an “address only” company (i.e., part of a shell company). Under EAR § 744.16, a license was required for exports of any items listed on the Commerce Control List. This action is a useful reminder that conducting a “ de minimis ” analysis is not a box-checking exercise and can be more complicated that it seems. When you assess the valuation of the controlled U.S.-origin item, it should reflect the fair market value of that item when it was exported from the United States and account for items customarily included (and actually shipped) with the controlled U.S.-origin item. BIS can view any attempts to “engineer” pricing to fall below the applicable de minimis thresholds as an evasion violation.

The settlement also underscores that exporters should not rely solely on name-based denied-party screening; address-only Entity List entries require address-level controls and, often, manual review. Companies should be sure that their screening providers both screen for these address-only Entity List entries and that their algorithms and fuzzy logic appropriately capture those addresses.

Lastly, the settlement is a good reminder that companies should be mindful of all license requirements and have in place disciplined recordkeeping processes when authorizations are obtained. Without these controls, U.S. export violations can quickly multiply.

Crowell & Moring will continue to monitor developments related to export control enforcement actions and their potential impact to industry.

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Crowell & Moring is a full-service international law firm that represents major businesses – both public and private – in complex high-stakes litigation, enforcement, regulatory and administrative, transactional matters, and government and internal investigations. Our Trade Law Blog features legal insight and thought-leadership affecting the industries and business reliant and affected by international trade.