Skip to main content

Collmann Griffin Discusses Enforcement Efforts Against Semiconductor Manufacturers in Kharon

Subtitle
"BIS Fined a U.S. Semiconductor Firm $252 Million for Illegal China Exports. Here's What Went Wrong"

Kharon

In this article, Collmann Griffin discussed the implications of the U.S. Bureau of Industry and Security's (BIS) $252 million penalty against Applied Materials Inc. and its South Korean subsidiary, arising out of sales of strategically important semiconductor manufacturing equipment to Semiconductor Manufacturing International Corporation (SMIC), China's premier semiconductor foundry. Griffin discussed the U.S. government's focus on exports of semiconductor manufacturing equipment and the mechanics of the relevant regulations, including the scope of items subject to the Export Administration Regulations (EAR) and the BIS Entity List. Griffin also discusses some of the national security and foreign policy concerns motivating the enforcement action. "When you're talking about something with such significant national security importance," Griffin said, "you have to make sure that your legal analysis is airtight."