Deborah Curtis Talks With Global Investigations Review on BIS Semiconductor Enforcement

Deborah Curtis, Co-Chair of Arnold & Porter’s White Collar Defense & Investigations practice, was recently quoted in the Global Investigations Review article, “Applied Materials settlement a ‘warning shot’ for US exporters.” The article examined the Bureau of Industry and Security’s (BIS) $252 million settlement with Applied Materials over exports tied to a restricted Chinese semiconductor company and discussed what it meant for the tech sector as Washington intensifies enforcement of sensitive technology exports.

“This is BIS laying down a marker that they are going to enforce semiconductor supply chain issues very, very strictly,” Deborah said.

“I see this as a really rigorous enforcement action,” she added, noting that the order signals the agency’s intent to apply export controls law as written. “You can’t solve an export control issue with a customs law answer.”

Deborah cautioned that companies should expect increased penalties going forward. “They’re really going to start levying heavy penalties,” she said.

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