The U.S Department of Commerce announced two settlements recently involving export control enforcement actions.

First, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $374,474 civil penalty against California-based satellite technology supplier Vizocom for unlawfully exporting controlled technical data related to military antennas to a Chinese manufacturer.

Second, (BIS) imposed a $1 million civil penalty against Teledyne FLIR, a U.S. manufacturer of thermal imaging cameras, for multiple violations of the Export Administration Regulations (EAR) involving exports to China and Hong Kong. The enforcement action highlights a recurring compliance challenge for multinational exporters: the complex application of the EAR’s de minimis rules, as well as the importance of careful screening and strict adherence to license conditions.