BIS Imposes $1.45M Penalties for Export Control Violations
Summary
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) announced two settlements totaling $1.45 million in civil penalties for export control violations. Vizocom was fined $374,474 for exporting technical data to China, and Teledyne FLIR was fined $1 million for multiple EAR violations involving exports to China and Hong Kong.
What changed
The Bureau of Industry and Security (BIS) has imposed significant civil penalties in two separate export control enforcement actions. Vizocom, a California-based satellite technology supplier, will pay $374,474 for unlawfully exporting controlled technical data related to military antennas to a Chinese manufacturer. Additionally, Teledyne FLIR, a U.S. manufacturer of thermal imaging cameras, has agreed to pay $1 million for multiple violations of the Export Administration Regulations (EAR), including exports to China and Hong Kong. These actions highlight the complexities of EAR's de minimis rules and the critical need for thorough screening and adherence to license conditions for multinational exporters.
These enforcement actions underscore the importance of robust export control compliance programs. Companies involved in exporting controlled technology or goods, particularly to China and Hong Kong, must carefully review their compliance procedures. This includes verifying the proper application of de minimis rules, conducting diligent screening of customers and end-users, and strictly adhering to all license conditions. Failure to do so can result in substantial civil penalties, as demonstrated by these settlements, and potential reputational damage. Companies should consider this a signal to reassess their internal controls and training related to export compliance.
What to do next
- Review export control compliance programs for adherence to EAR, especially regarding de minimis rules.
- Enhance screening processes for customers and end-users involved in exports to China and Hong Kong.
- Ensure strict adherence to all export license conditions.
Penalties
Vizocom: $374,474 civil penalty. Teledyne FLIR: $1 million civil penalty. Total penalties: $1,374,474.
Source document (simplified)
March 25, 2026
Episode 401 — Commerce Department’s Recent Export Controls Enforcement Actions
Mike Volkov The Volkov Law Group + Follow Contact LinkedIn Facebook X Send Embed
The U.S Department of Commerce announced two settlements recently involving export control enforcement actions.
First, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $374,474 civil penalty against California-based satellite technology supplier Vizocom for unlawfully exporting controlled technical data related to military antennas to a Chinese manufacturer.
Second, (BIS) imposed a $1 million civil penalty against Teledyne FLIR, a U.S. manufacturer of thermal imaging cameras, for multiple violations of the Export Administration Regulations (EAR) involving exports to China and Hong Kong. The enforcement action highlights a recurring compliance challenge for multinational exporters: the complex application of the EAR’s de minimis rules, as well as the importance of careful screening and strict adherence to license conditions.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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