By Kristine Kelleher, Export Solutions
Is it just me, or does it seem like every day there is new activity through the Bureau of Industry and Security, Office of Export Enforcement (BIS-OEE)? OEE seems to be everywhere, fixated with ghoulish intensity on raising a graveyard of penalties. Let’s take a closer look at some examples and review the highlights from BIS’ 2025 Annual Report to Congress.
Examples of Export Enforcement
Haunting of the C-Suite
“United States v. Liaw, et. al. – Charged in the Southern District of New York in March 2026, BIS-OEE was the co-lead investigative agency in this landmark criminal diversion scheme. The indictment accuses the defendants, including Wally Liaw – the co-founder, executive vice president, and member of the board, of conspiring to unlawfully export $2.5 billion of servers manufactured by Super Micro to China through cut-out companies in Southeast Asia. If convicted, the defendants face up to 20 years’ imprisonment.”
Beware of the Shape-Shifters
“M&M Wireless – Attempted to evade export controls by making false and misleading statements and falsified material facts for the purpose of undervaluing exports and failed to comply with recordkeeping requirements. The result? A Settlement Agreement where export privileges are denied for 3 years, all of which are suspended, assuming completion of export compliance training on the Export Regulations within a 12-month timeframe.”
Vampire Logistics
Azur Air – Temporary Denial Order for the transshipment of U.S.-origin goods to Russia by communicating with parties in Russia and Turkey to instruct them on how to circumvent U.S. export controls, falsifying shipping documentation, and utilizing freight forwarders located abroad to transship items to Russia. This was in addition to their violations just 8 months prior, where they were involved in prohibited conduct by operating aircraft subject to the EAR on flights into Russia without the required BIS authorizations.
A Toxic Brew
Luminultra Technologies, Inc. – Sold and exported 3 PhotonMaster luminometers and 25 aqueous test kits, designated as EAR99 items and valued at $33,661, with knowledge that the items were destined to Iran without the required license and made false and misleading representations, statements, and certifications, in connection with the submission of an EEI filing. BIS hit them with a Settlement Agreement including a civil penalty of $685,051, a requirement to complete export compliance audits annually for three years, mandating that employees complete export compliance training, and the company be subject to a three-year suspended denial of export privileges.
The Book of Spells
Cadence Design Systems, Inc. – Exported, and later transferred or attempted to transfer, Electronic Design Automation (EDA) hardware and software and semiconductor design technology, which included EAR99 classifications, valued at $45,305,317.41 to BIS Entity List party National University of Defense Technology (NUDT) in China under the alias Central South CAD Center (CSCC) with knowledge or reason to know that violations would occur. Like the other examples, they are also under a Settlement Agreement including a civil penalty of $95,312,000, of which $47,656,000 shall be suspended until criminal penalty payment is made to the U.S. Department of Justice, and completion of 2 internal audits of its export control compliance program.
Skeleton Keys
Alpha and Omega Semiconductor Incorporated – Exported approximately 1,650 EAR99 power controllers, smart power stages, and demo boards to an entity on the BIS Entity List, with knowledge that violations would occur. They too were placed under a Settlement Agreement with a civil penalty of $4,250,000.
Highlights from BIS’ 2025 Annual Report to Congress
Let’s take a closer look at BIS’ 2025 Annual Report to Congress, unmasked as a corporate horror story where regulators are hunting down supply chain ghosts and resurrecting lethal penalties.
Bloodbath of Penalties
BIS imposed a staggering $324 million in combined civil and criminal penalties in 2025. This is a monstrous, blood-chilling leap from the mere $16 million collected the year before.
The Reaper’s Tally
BIS completed 53 administrative enforcement slaughters, yielding over $108 million in civil fines. Their dark ledger also boasts 455 warning letters, 705 cargo detentions, 232 asset seizures, 29 banishing denial orders, and criminal investigations that dragged executives into 65 convictions.
Banished to the Shadow Realm
BIS added 142 new entities to the Entity List, heavily targeting foreign high-performance computing, quantum tech, and Iranian drone procurement networks.
Haunting the Globe
To make sure American tech isn’t being used to build foreign nightmares, invisible agents conducted 1,840 end-use checks spanning 73 countries, materializing at foreign shipping docks to audit buyers.
Unleashing the Enforcement Horde
BIS investigations resulted in the criminal convictions of 65 individuals and companies for export violations in 2025. These cases led to $83,959,508 in criminal fines, $81,526,291 in forfeitures, $5,270,566 in restitution, and 2,668 months of imprisonment.
The successes are continuing in 2026, including a major ramp-up in Export Enforcement personnel and several additional landmark enforcement actions. And judging by these bone-chilling numbers, we can assume this monster will only continue to grow.
If these statistics scare you, contact Export Solutions to schedule a no-charge consultation today! Let us help you uncover any export compliance nightmares that could be lurking in the shadows so you don’t become the next OEE victim.
Kristine Kelleher is a Trade Compliance Consultant for Export Solutions -- a full-service consulting firm specializing in U.S. import and export regulations.
