Commerce Imposes Largest-Ever Penalty for Violations Related to the Entity List, Foreign Direct Product Rule
On Thursday, the Department of Commerce’s Bureau of Industry and Security (BIS) announced 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 7.4 million units of foreign origin hard drives (HDD), valued at approximately $1.1 billion, to Huawei Technologies Co. Ltd. (Huawei), a party in China that is on the BIS Entity List. 
If you have any questions, please contact Daniel E. Goren or Sean C. Koehler.
Daniel E. Goren
Partner
203.498.4318
Sean C. Koehler
Counsel
203.498.4301
Follow Wiggin and Dana LLP on LinkedIn and Twitter for more content like this.
© 2023 Wiggin and Dana LLP. In certain jurisdictions this may constitute attorney advertising.