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U.S. BIS imposes civil penalty on company for shipping semiconductor wafers to company on Entity List

Unauthorized shipments of semiconductor wafers to a Chinese entity on the BIS Entity List, due to a data entry error

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November 1, 2024

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today announced a $500,000 civil penalty on a semiconductor manufacturing company headquartered in New York and its subsidiary for shipping semiconductor wafers worth $17.1 million to a company on the BIS Entity List, without the required license.

According to the BIS release, the semiconductor manufacturing company voluntarily disclosed the violation, cooperated with the investigation, and took corrective actions, leading to a reduced penalty.

Between February 2021 and October 2022, the semiconductor manufacturing company violated the Export Administration Regulations (EAR) by sending 74 separate shipments of semiconductor wafers, collectively valued at approximately $17.1 million, to a company on the BIS Entity List, without the requisite license or other authorization from BIS. Due to a data entry error, the company on the Entity List was not properly identified in semiconductor manufacturing company’s transaction screening system.

For more information, contact a professional with KPMG Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
Principal
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
E: aahanchian@kpmg.com

Christopher Young
Principal
E: christopheryoung@kpmg.com

Gisele Belotto
Principal
E: gbelotto@kpmg.com

George Zaharatos
Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
Principal
E: jlibby@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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