Export Violations and Remediation
Complying with US export regulations can be surprisingly tricky: at various times in the 2010s and 2020s I've had to be hip-deep in them as part of my various roles. Today I'll focus on an urgent assignment I was handed in late 2024. Normally I don't explicitly name my former employer when talking about projects, but I'll be referring to certain public documents so it'll be pretty obvious this time. Also, the US State Department files are exclusively downloadable PDFs, as far as I know you can't just view them online, sorry. "Uh-oh" In late 2024 my boss pulled me into a meeting to ask how I could help with an urgent project. The company had just negotiated a consent agreement and $200M fine for export violations to China, and I was one of the people who would help with the urgent work of ensuring that we weren't going to find any further violations and identifying any programs or product lines with any export-regulations risk in China. This i...