Overview
- U.S. authorities announced on Wednesday that the Justice Department’s National Security Division declined to prosecute Robert Bosch GmbH under the new Corporate Enforcement and Voluntary Self‑Disclosure Policy, and the Commerce Department’s Bureau of Industry and Security imposed a $36,184,680 civil penalty.
- Investigators found that two Bosch non‑U.S. subsidiaries, Bosch Sensortec GmbH and ETAS GmbH, exported more than $70 million in MEMS sensors and foreign‑produced software to Huawei on over 100 occasions between September 2020 and September 2024 without required Commerce licenses.
- Bosch voluntarily self‑disclosed the conduct, fully cooperated, preserved and produced documents, and implemented remedial steps including organizational changes and expanded trade compliance staff, which led to DOJ’s declination and a required disgorgement of $11,430,098 in profits to be credited toward the BIS fine.
- The action rests on the Foreign Direct Product Rule, which extends U.S. export controls to foreign‑made items that are the direct product of U.S. technology, meaning non‑U.S. subsidiaries can face U.S. enforcement when U.S. tech underlies their products.
- Officials say the case demonstrates the practical effect of the DOJ policy in rewarding prompt disclosure and cooperation and signals tougher oversight for global supply chains, likely raising compliance costs and scrutiny for companies that use U.S. technology.