Robert Bosch GmbH just wrote one of the more expensive apology letters in recent corporate memory. The German engineering conglomerate has agreed to pay $36.18 million in civil penalties to the US Department of Commerce’s Bureau of Industry and Security after shipping products to Huawei Technologies without the required licenses.
The shipments totaled approximately $72.4 million in value and included Micro-Electro-Mechanical Systems (MEMS) sensors and automotive software. They occurred on more than 100 separate occasions between September 16, 2020, and September 26, 2024.
What Bosch actually did
Huawei has been on the US Entity List since 2019, which means any company shipping US-origin technology, or technology produced using certain US tools and know-how, needs an explicit license from BIS.
The violations fall under the Foreign Direct Product Rule, a regulation that extends US export controls beyond American borders. Even if Bosch is a German company making products in non-US facilities, the rule can still apply if the underlying technology has a sufficient American nexus.
