The Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) have been flexing their muscles with record enforcement actions.
BIS imposed a $300 million civil penalty against Seagate Technology LLC for the company’s apparent violations of US export controls when continuing to sell hard disk drives to Huawei Technologies Co. Ltd. after the August 2020 foreign direct product rule was extended to certain item...
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