Latest / Trade Compliance Brief - Export Control and Sanctions Insights
The $1.7M Export Lesson: Coastal PVA Technology and the SMIC Entity List Trap
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
The skinny
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