The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry and Security imposed significant penalties for violations.
BIS Case
On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a publicly traded designer and supplier of power semiconductors headquartered in Sunnyvale, California.
The agency concluded that AOS committed fifteen violations of the Export Administration Regulations (“EAR”) between May and November 2019 by exporting a range of EAR99-designated items—namely smart power stages, power controllers, and related accessories—from the United States to Huawei Technologies Co., Ltd. (“Huawei”), a foreign company designated on the Entity List.
Of the fifteen discrete violations, BIS determined that eleven were undertaken with actual knowledge, or at minimum, a reason to know, that the conduct in question contravened U.S. export control requirements. The enforcement action culminated in a civil penalty of $4.25 million, payment of which is now a condition for the maintenance or renewal of any export license or privilege granted to AOS.
OFAC Case
On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and freight forwarding firm headquartered in Delaware, to resolve Key Holding’s potential civil liability for apparent violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. part 515. The apparent violations stemmed from the activities of Key Holding’s Colombian subsidiary, Key Logistics Colombia S.A.S. (“Key Colombia”), which managed the logistics for dozens of shipments to Cuba over an 18-month period. While OFAC determined that the apparent violations were not egregious and were voluntarily self-disclosed, the settlement—totaling $608,825—reflects a calculated response to serious compliance deficiencies that occurred after Key Colombia became subject to U.S. jurisdiction as a result of its acquisition by a U.S. person.
