$2.78 Million Penalty for Illegal Aerospace and Military Exports to China and Germany

As part of a settlement agreement, the Bureau of Industry and Security has imposed an administrative penalty of $2.78 million on a 3D printing company for illegal exports to China and Germany, including aerospace and military design documents. The company will also be required to retain a third-party consultant and complete two audits of its export controls compliance program.

This settlement resolves allegations regarding 19 violations of the Export Administration Regulations by this 3D printing company by exporting controlled aerospace technology and metal alloy powder to China without the required license, as well as by exporting controlled technology to Germany without the required license. In addition, the company failed to comply with the EAR’s recordkeeping requirements.

BIS states that the company e-mailed controlled design drawings, including those for military electronics and those used in the development, production, operation, or repair of spacecraft, to its then-subsidiary’s office in Guangzhou City, China. The company also exported controlled design documents to Germany, where it maintained a mirrored server to store employee emails containing controlled technology. In addition to unlicensed exports via e-mail, the company exported metal alloy powder, which is controlled for national security and nuclear nonproliferation reasons, to China without the required license.