BIS fines Bosch over $36 Million for Unauthorized Exports to Huawei

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) announced a settlement requiring Robert Bosch GmbH to pay a $36,184,680 penalty for export control violations. Between September 2020 and September 2024, Bosch exported roughly $72.3 million worth of MEMS sensor products and automotive software to Huawei and its affiliates without the necessary BIS authorization, violating the Foreign Direct Product Rule under the Export Administration Regulations. Because the company filed a Voluntary Self-Disclosure and cooperated with investigators, BIS suspended approximately $3.6 million of the penalty as credit toward Bosch's separate profit disgorgement agreement with the Department of Justice. Simultaneously, the Department of Justice's National Security Division announced its first-ever declination of prosecution under the Corporate Enforcement Policy regarding the same conduct. Because Bosch voluntarily self-disclosed these Foreign Direct Product Rule violations, fully cooperated, and overhauled its compliance program, it successfully avoided criminal charges. As part of the resolution, Bosch agreed to disgorge $11.4 million in illicit profits to the DOJ, a portion of which BIS will credit toward its separate civil penalty