U.S. company agrees to pay $374,000 for unauthorized export of military technology to China

The Bureau of Industry and Security (BIS), U.S. Department of Commerce, today announced that it has imposed a civil penalty against a U.S. entity following its admission to violating the Export Administration Regulations (EAR) by exporting controlled military technology to China without the required license.

Summary

According to the BIS order:

• In May 2019, the entity transferred specifications for a U.S. manufacturer’s very high frequency/ultra-high frequency (VHF/UHF) antenna—designed exclusively for military radios and controlled under Export Control Classification Number (ECCN) 3E611—to a Chinese manufacturer. These specifications constituted technology subject to the EAR and required a BIS license for export to China, with no license exceptions available. The U.S. entity did not seek or obtain such a license.
• The U.S. entity subsequently purchased antennas manufactured by the Chinese company based on the uploaded specifications and supplied 450 of these antennas to the U.S. Navy. The antennas were repackaged and accompanied by a specification sheet falsely representing the identity of the manufacturer. The entity received $165,109.50 for the transaction. The Navy’s original Request for Proposal (RFP) required the awardee to be an authorized distributor or reseller of antennas from a specific U.S. company, with no substitutes permitted.
• As part of a settlement agreement, the U.S. company has been assessed a civil penalty of $374,474, payable in 20 quarterly installments from March 15, 2026, through December 15, 2030. Additionally, the entity is subject to a five-year denial of export privileges under the EAR, suspended during a probationary period and to be waived upon full and timely payment and compliance with the regulations. If the entity fails to comply, the denial may be activated, restricting its ability to participate in any export-related transactions involving items subject to the EAR.