UNICORN PRIVATE Sanctions and export control fines for electronics and dual-use goods
In short
Published cases on this page: 6. Authorities: 4. Years: 2023 to 2026.
In the United States (OFAC, BIS) and in the United Kingdom (OFSI, since 15 June 2022) civil liability is strict: a company can be fined even if it did not know that the counterparty was sanctioned.
Amounts are shown in the currency of the decision and are never converted.
Cases
Cases shown: 6 of 6
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Extreme Networks, Inc.Civil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | OFAC (US Treasury) + DOJ (US Department of Justice) | OFAC: $1,529,685 DOJ: $975,721.84 |
Through its Russian subsidiary Extreme sold networking equipment to a company majority-owned by a sanctioned Russian air-defence maker. Official source verified on November 13, 2026 | |
| Illumina Cambridge LimitedCompound settlement (not a conviction) | United Kingdom | Electronics and dual-use goods | HMRC | £7,438,840.13 | The company was involved in moving sanctioned goods between two overseas group companies, with the goods going to Russia. Official source verified on November 13, 2026 | |
| Applied Materials Inc. and Applied Materials Korea, Ltd.Civil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | BIS (US Department of Commerce) | about $252,000,000 | The company shipped ion implanters without a licence to a Chinese company on the Entity List, routing them through its Korean subsidiary. Official source verified on November 13, 2026 | |
| Cadence Design Systems Inc.Guilty plea (DOJ) and BIS penalty | United States | Electronics and dual-use goods | DOJ (US Department of Justice) + BIS (US Department of Commerce) | more than $140,000,000 | Cadence and its Chinese subsidiary exported controlled chip-design tools without licences to a Chinese military university on the Entity List, through an alias. Official source verified on November 13, 2026 | |
| Harman International Industries, Inc.Civil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | OFAC (US Treasury) | $1,454,145 | Employees of a Harman subsidiary let its UAE distributor divert Harman products to Iran. Official source verified on November 13, 2026 | |
| Seagate Technology LLCCivil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | BIS (US Department of Commerce) | $300,000,000 | Seagate supplied hard disk drives to Huawei, which is on the Entity List, in breach of the foreign direct product rule. Official source verified on November 13, 2026 |
Select a column heading to sort the table. Amounts are shown in the currency of the decision and are never converted.
Totals by year and by authority
Sums of the amounts imposed on companies in this list, by currency, never converted. Not included: breaches published without a fine, anti money laundering penalties, confiscations and amounts imposed on individuals. A total marked about or more than includes an amount that the source gives as approximate or as a minimum.
By year
| Year | Cases | Total |
|---|---|---|
| 2026 | 3 | about $254,505,406.84; £7,438,840.13 |
| 2025 | 2 | more than $141,454,145 |
| 2023 | 1 | $300,000,000 |
By authority
| Authority | Cases | Total |
|---|---|---|
| BIS (US Department of Commerce) | 2 | about $552,000,000 |
| OFAC (US Treasury) | 2 | $2,983,830 |
| DOJ (US Department of Justice) | 1 | $975,721.84 |
| DOJ (US Department of Justice) + BIS (US Department of Commerce) | 1 | more than $140,000,000 |
| HMRC | 1 | £7,438,840.13 |
Frequently asked questions
Have companies in this sector been fined for sanctions violations?
This page lists 6 published cases. The largest amounts are: Seagate Technology LLC (BIS (US Department of Commerce), April 19, 2023): $300,000,000; Applied Materials Inc. and Applied Materials Korea, Ltd. (BIS (US Department of Commerce), February 11, 2026): about $252,000,000; Cadence Design Systems Inc. (DOJ (US Department of Justice) + BIS (US Department of Commerce), Guilty plea (DOJ) and BIS penalty, July 28, 2025): more than $140,000,000; Illumina Cambridge Limited (HMRC, Compound settlement (not a conviction), September 8, 2026): £7,438,840.13.
Can a company be fined without knowing that the counterparty was sanctioned?
In the United States and in the United Kingdom, yes, for civil penalties. OFAC states that a US person may be held civilly liable even without having knowledge or reason to know of the violation; BIS civil liability is also strict; since 15 June 2022 OFSI no longer has to prove that a person knew or had reasonable cause to suspect. In the EU the directive requires intent, and serious negligence is enough for military and dual-use goods. In Canada a wilful violation is required. Example from this list: Pegasus Worldwide Logistics (OFAC, 9 October 2026) arranged a shipment of equipment from a sanctioned Chinese supplier without noticing, because of gaps in its checks.
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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
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