# ExChek Audit — Complete Structured Content > Free export compliance assessment and BIS enforcement analysis ## Site Information - URL: https://audit.exchek.us - Parent Company: ExChek, Inc. (Dover, DE) - Main Site: https://exchek.us - Documentation: https://docs.exchek.us - API: https://api.exchek.us - Enterprise: https://enterprise.exchek.us - GitHub: https://github.com/exchekinc/exchekskills - Twitter: @ExChekOrg --- ## Purpose The ExChek Audit site is a content-led evangelism platform that educates companies about export compliance risks through real enforcement data, self-assessment tools, and a free compliance audit lead magnet. It converts prospects into ExChek Engine users. --- ## Enforcement Statistics (Verified from Official Records) - **$300M** — Largest single BIS civil penalty ever (Seagate Technology, April 2023) - **$252M** — Second-largest BIS penalty (Applied Materials, February 2026) - **$374,474** — Maximum civil penalty per violation as of 2025 (or twice the transaction value, whichever is greater) - **$1M per violation** — Maximum criminal fine per violation - **20 years** — Maximum criminal imprisonment per violation - **26+** Disruptive Technology Strike Force criminal cases since February 2023 inception (15 in 2024 alone) - **17** DTSF location units across the US - Penalties are assessed **per violation** — each shipment counts separately - BIS ended "no admit, no deny" settlement policy — companies must now admit factual conduct --- ## Enforcement Case Studies (All Verified from Official Records) ### 1. Seagate Technology - **Penalty:** $300M Civil Penalty (April 2023) - **Violation:** EAR 744 — Entity List violations (429 counts) - **Summary:** Shipped approximately 7.4 million hard disk drives worth $1.1 billion to Huawei after Huawei was added to the Entity List. BIS found 429 separate violations over a sustained period. Largest BIS civil penalty ever imposed. - **Source:** BIS Press Release, April 19, 2023 ### 2. Applied Materials - **Penalty:** $252M Civil Penalty (February 2026) - **Violation:** EAR 744 — Entity List violations (56 counts) - **Summary:** Semiconductor equipment maker penalized for 56 violations involving illegal reexport of ion implanting equipment to SMIC in China via South Korea subsidiary. Penalty equals twice the $126.3M transaction value (statutory maximum). Second-largest BIS penalty ever. - **Source:** BIS Press Release, February 12, 2026 ### 3. Cadence Design Systems - **Penalty:** $140M+ Combined ($72.5M fine + $45.3M forfeiture criminal; $91.3M civil) (July 2025) - **Violation:** EAR — 61 violations, unlicensed exports to Entity List - **Summary:** EDA software company pled guilty to conspiracy for selling hardware, software, and semiconductor design IP to the National University of Defense Technology (NUDT), a Chinese military university on the Entity List, through a third-party intermediary from 2015-2021. - **Source:** DOJ / BIS Enforcement Action, July 28, 2025 ### 4. 3D Systems Corporation - **Penalty:** $27.3M Combined ($2.77M BIS + $20M DDTC + $4.54M DOJ) (February 2023) - **Violation:** EAR + ITAR — Unlicensed technology exports to China - **Summary:** 3D printing company emailed technical blueprints for aerospace and military electronics to its subsidiary in Guangzhou, China from 2012-2019. Settled with three agencies simultaneously. - **Source:** BIS / State / DOJ Joint Settlement, February 2023 ### 5. Haas Automation - **Penalty:** $2.5M Combined BIS + OFAC (January 2025) - **Violation:** EAR 764 — Entity List violations (41 counts) - **Summary:** CNC machine tool manufacturer fined for 41 EAR violations involving export of machine parts to Entity List parties in Russia and China. The parts were valued at just $29,254 — but BIS assessed penalties 85x the transaction value. - **Source:** BIS / OFAC Settlement, January 2025 ### 6. Exyte Management GmbH - **Penalty:** $1.5M Civil Penalty (January 2026) - **Violation:** EAR 764 — Causing EAR-controlled transfers to Entity List - **Summary:** German semiconductor cleanroom builder penalized for 13 violations involving transfers of EAR-controlled items to Entity List parties. Demonstrates BIS enforcement reach extends to foreign companies handling US-origin technology. - **Source:** BIS Civil Penalty, January 2026 ### 7. LuminUltra Technologies - **Penalty:** $685K Civil Penalty (October 2025) - **Violation:** EAR — Iran embargo violations, concealment - **Summary:** Canadian biotech company exported luminometers (water quality testing equipment) to Iran, deliberately concealing the true destination by routing shipments through a UAE freight forwarder. - **Source:** BIS Civil Penalty, October 2025 --- ## Compliance Checklist (Most Companies Fail) 1. **Do you export products, technology, or software outside the US?** — Even cloud access by foreign nationals counts as an export under EAR deemed export rules. 2. **Have you formally classified every item you export with an ECCN?** — "We just mark everything EAR99" is the #1 compliance failure BIS finds during audits. 3. **Do you screen every customer, consignee, and end-user against the CSL?** — Entity List, SDN, Denied Persons, Unverified List — one miss is a violation. 4. **Do you have a written Export Compliance Program (ECP)?** — BIS offers significant penalty mitigation for companies with an ECP. Without one, penalties are maximized. 5. **Can you produce classification records for the last 5 years?** — 15 CFR 762 requires 5-year retention. 6. **Do your foreign-national employees have Technology Control Plans?** — Sharing controlled technology with foreign nationals in the US is a deemed export. 7. **Do you know your red flags?** — BIS Supp. 3 to Part 732 lists specific red flags. 8. **Have you done a retrospective audit / lookback in the last 12 months?** — Voluntary self-disclosure drastically reduces penalties. --- ## BIS Enforcement Tracker (Verified Actions) | Date | Entity | Action | Penalty | Regulation | |------|--------|--------|---------|------------| | Feb 2026 | Applied Materials | Civil Penalty | $252M | EAR 744 | | Feb 2026 | Teledyne FLIR | Civil Penalty | $1M | EAR | | Feb 2026 | Vizocom | Civil Penalty | $374K | EAR | | Jan 2026 | Exyte Management GmbH | Civil Penalty | $1.5M | EAR 764 | | Oct 2025 | LuminUltra Technologies | Civil Penalty | $685K | EAR | | Jul 2025 | Cadence Design Systems | Guilty Plea + Civil | $140M+ | EAR | | Jan 2025 | Haas Automation | Civil Penalty (BIS + OFAC) | $2.5M | EAR 764 | | 2024 | TE Connectivity | Civil Penalty | $5.8M | EAR | | Apr 2023 | Seagate Technology | Civil Penalty | $300M | EAR 744 | | Feb 2023 | 3D Systems Corporation | Multi-Agency Settlement | $27.3M | EAR + ITAR | Sources: BIS press releases, DOJ announcements, Federal Register notices, OFAC SDN updates. --- ## How ExChek Closes Every Gap ### ECCN Classification Formal ECCN classification for every item using live eCFR data. No more guessing EAR99. ### Denied Party Screening Real-time screening against all 14 USG restricted party lists: Entity List, SDN, DPL, Unverified — all of them. ### License Determination Country Chart analysis, License Exception eligibility (TMP, TSR, LVS, BAG, ENC), and application guidance. ### Red Flag Assessment Automated BIS Supp. 3 red flag checklist for every transaction. Catch diversion indicators before they become violations. ### Export Documentation SLI, commercial invoices, AES/EEI data elements — generated automatically with audit-ready formatting. ### Retrospective Audit Lookback analysis across historical shipments. Find violations before BIS does and file voluntary self-disclosures. --- ## Free Compliance Audit Sign up at https://audit.exchek.us/#audit with your work email. - Personalized assessment based on industry, products, and destinations - No sales call required - Compliance scorecard delivered within 48 hours - Specific action items and risk areas --- ## ExChek Engine Installation ``` claude install-skill https://github.com/exchekinc/exchekskills ``` 16 skills covering the full export compliance lifecycle: classify, csl, license, export-docs, ecp, risk-triage, encryption, jurisdiction, country-risk, deemed-export, red-flag-assessment, partner-compliance, recordkeeping, audit-lookback, compliance-report, docx --- ## FAQ **Q: Who needs export compliance?** A: Any US company that exports products, software, or technology — including cloud-hosted software accessed by foreign nationals. Foreign companies handling US-origin items are also subject to EAR. **Q: What is a Temporary Denial Order (TDO)?** A: A TDO immediately revokes a company's ability to export. BIS can issue one without a trial. Quicksilver Manufacturing has been under a TDO since June 2022. **Q: What are the maximum penalties?** A: Civil: $374,474 per violation or twice the transaction value. Criminal: $1M per violation and 20 years imprisonment. Penalties are per-violation — each shipment counts separately. **Q: Can small companies really get fined millions?** A: Yes. Haas Automation was fined $2.5M for CNC parts worth just $29,254. Penalties are based on violation severity, not company size. **Q: What does the free audit include?** A: Classification gaps, screening coverage, recordkeeping, ECP evaluation, and specific risk areas based on your industry and export destinations. **Q: How is ExChek different from hiring a consultant?** A: ExChek runs continuously in your AI workflow for $0 vs $50K+ for a consultant engagement. **Q: What if we find violations during the audit?** A: VSD (Voluntary Self-Disclosure) significantly reduces penalties. Finding violations proactively protects your company. **Q: What is the Disruptive Technology Strike Force?** A: Launched February 2023 by DOJ and Commerce, the DTSF targets illicit technology transfers. 26+ criminal cases in its first two years (15 in 2024 alone), expanded to 17 location units. **Q: Has BIS enforcement changed recently?** A: Yes. BIS ended its "no admit, no deny" settlement policy. Companies must now admit factual conduct. Commerce Secretary Lutnick pledged a "dramatic increase" in enforcement. The Applied Materials ($252M) and Cadence ($140M+) penalties in 2025-2026 signal record-level enforcement. --- ## Contact - Email: matt@exchek.us - Twitter: @ExChekOrg - Website: https://exchek.us