Trade Compliance Brief - Export Control and Sanctions Insights

The $1.7M Export Lesson: Coastal PVA Technology and the SMIC Entity List Trap


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In this episode, we break down the April 2026 BIS enforcement action against Coastal PVA Technology, Inc.. Learn how 18 violations involving EAR99 semiconductor brushes led to a $1.7 million civil penalty. We explore the dangers of "knowledge" in third-party distributions , the specific risks of shipping to SMIC Beijing and SMIC North , and why "no formal compliance program" is a defense the government won't accept.


Charging Letter: https://www.bis.gov/media/documents/coastal-pva-technology-inc-4-13-2026-rev.pdf

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Trade Compliance Brief - Export Control and Sanctions InsightsBy Pete