WASHINGTON, D.C. — Today, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement agreement with Robert Bosch GmbH (Bosch), headquartered in Stuttgart, Germany, covering shipments of foreign-produced items to Huawei Technologies Co. (Huawei), or its affiliates. 

Between September 16, 2020 and September 26, 2024, Bosch exported from abroad approximately $72,369,361 worth of Micro-Electro-Mechanical Systems (“MEMS”) sensor products and automotive software for cell phones, items subject to the Export Administration Regulations (the EAR) pursuant to the Foreign Direct Product Rule, to Huawei and its affiliates on the Entity List without the required license or other authorization from BIS.  The MEMS sensors at issue have a broad range of consumer applications, including in smartphones, wearable technology, and automobiles.

Bosch filed a Voluntary Self-Disclosure and cooperated with the investigation.

Bosch agreed to pay a penalty of $36,184,680. Bosch also agreed with the Department of Justice to disgorge profits, partially suspended, with actual payment of approximately $3.6 million.  BIS is suspending approximately $3.6 million of its penalty as credit for the disgorgement.

Assistant Secretary of Commerce for Export Enforcement David Peters stated: “Bosch had several opportunities to avoid these violations had they exercised the increased vigilance BIS has repeatedly said it expects of companies whose transactions are governed by the EAR. Today’s action should serve as a warning to embrace compliance and as an example of the benefits of voluntary self-disclosure.”

The full order, settlement agreement, and Proposed Charging Letter are available online here.  This case was investigated by BIS’s Office of Export Enforcement, New York Field Office. For more information, please visit https://www.bis.gov/enforcement.

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