Trade Compliance Brief - Export Control and Sanctions Insights

Unlicensed Tech Data Exports: Breaking Down the Vizocom ICT EAR Violation


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Did you know that uploading a technical drawing to an offshore supplier portal is legally the exact same as shipping a controlled item across the border?

In this episode of The Trade Compliance Brief, we break down the February 2026 Bureau of Industry and Security (BIS) Final Order against Vizocom ICT. What started as a routine procurement effort for military radio antennas turned into a massive Export Administration Regulations (EAR) violation, a deliberate supply chain cover-up, and a $374,474 civil penalty.

We dissect the critical mistakes made by Vizocom, starting with uploading 600-series (ECCN 3E611) technical data to a Chinese manufacturing portal. We also explore the fallout of attempting to "origin wash" the resulting components to hide their PRC origins from government customers.

What you’ll learn in this episode:

  • The RFQ Trap: Why requests for quote on platforms like "Made in China" are heavily scrutinized exports.
  • The 600-Series Reality: The severe restrictions surrounding military-grade technical data and the PRC.
  • Origin Washing: Why repackaging foreign-made goods to obscure their origin compounds your legal exposure.
  • Actionable Advice: How to align your procurement and purchasing teams with your export control program before they click upload.

Resources Mentioned:

  • Read the full BIS Final Order here: https://www.bis.gov/media/documents/vizocom-ict-final-order-2-24-2026.pdf

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Trade Compliance Brief - Export Control and Sanctions InsightsBy Pete