On 19 April 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced1 that it had imposed a $300 million civil penalty – the largest standalone administrative penalty in BIS history – against Seagate Technology LLC of Fremont, California and Seagate Singapore International Headquarters Pte. Ltd. of Singapore (“Seagate”), for 429 violations of the Export Administration Regulations (“EAR”) involving the company’s sale of foreign-origin hard disc drives (“HDD”) to...
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