Background

The Department of Justice reports that on Feb. 18 a Bulgarian national was sentenced in a federal court in Austin, Texas, to 38 months time served for conspiracy to violate the IEEPA.

According to court documents, in August 2014 this person began working at a Bulgarian company created to enable two Russian companies to acquire U.S.-origin radiation-hardened and high-temperature electronic circuits from a company based in Austin. Earlier in 2014, following Russia’s invasion of Crimea, the U.S. imposed export controls that made it illegal to export those goods directly to Russia without a license from BIS.

In January 2015, the Bulgarian entity received a 16mB SRAM wafer from a U.S. supplier in Austin. Approximately one month later, the Bulgarian entity entered into a written contract to deliver the parts to a Russian engineering company and over the next three months the Russian entity transferred more than $1 million split into three separate payments to the Bulgarian entity. After receiving the third payment, the Bulgarian entity issued a $158,125 invoice for the sale of the Austin-based supplier’s parts to the Russian company. The Bulgarian entity thereafter shipped the parts to the Russian entity in Russia, in violation of the Export Administration Regulations and the IEEPA.

The Justice Department indicates that between May 2014 and May 2018 a total of six wafers were shipped as part of the scheme for a total of approximately $497,000. When diced, one wafer creates approximately 180 individual chips.

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