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The $252M Mistake: Inside the Applied Materials & SMIC Settlement
In this episode of the Trade Compliance Brief, we break down the massive $252.5 million administrative penalty issued by the Bureau of Industry and Security (BIS) against semiconductor giant Applied Materials (AMAT).
We dissect the failed "dual-build" strategy, where AMAT shifted the assembly of ion implanter equipment from Gloucester, Massachusetts, to South Korea in an attempt to continue selling to SMIC after it was placed on the Entity List.
Key takeaways include:
The Compliance Trap: Why AMAT’s reliance on "substantial transformation" was legally incorrect and how it…
The skinny
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