Key Takeaways
- • Lamda Research Corporation settled with the BIS for $2 million in civil penalties (fully suspended for one year) over 66 Export Administration Regulations (EAR) violations, including unauthorized exports of software-embedded USB dongles and maintenance subscriptions to Huawei Technologies Japan and other sanctioned entities between April 2021 and August 2025.
- • Unauthorized Huawei exports dominated the violation count: Lamda shipped CodeMeter dongles containing TracePro, OSLO, IGES, and STEP software to Huawei Japan on five occasions and transmitted 47 automatic software updates across two products, all without required BIS authorization despite knowing Huawei Japan's Entity List status.
- • Secondary violations involved two other restricted parties: Lamda sold 15 TracePro licenses to Shenzhen SiCarrier (later added to Entity List in December 2024) with seven automatic updates, and exported software to Southern Marine Science and Engineering Laboratory at Sun Yat-Sen University without obtaining required Unverified List (UVL) statement.
- • URAL Airlines JSC's Temporary Denial Order renewed for one year (effective September 24, 2026, publicly released in October 2026) due to continued violations involving operation of controlled aircraft (ECCN 9A991.b) on Russia-bound flights from Central Asian destinations after March 2022, with evidence of non-compliance through September 2025.
Summary
The Bureau of Industry and Security (BIS) has issued two significant enforcement actions targeting export control violations. Lamda Research Corporation, a software licensing company, agreed to a $2 million settlement for systematically exporting controlled software and maintenance services to sanctioned Chinese entities over a four-year period. The violations centered on CodeMeter USB dongles containing optical design and engineering software (TracePro, OSLO, IGES, and STEP) shipped to Huawei Technologies Japan, a party on the BIS Entity List. Between April 2021 and August 2025, Lamda made five direct exports to Huawei Japan and transmitted 47 automatic software updates without authorization, with knowledge that Huawei Japan was restricted. Beyond Huawei, Lamda sold 15 TracePro licenses to Shenzhen SiCarrier between May and September 2024—before SiCarrier's December 2024 Entity List designation—and transmitted seven updates post-designation. The company also failed to obtain a required Unverified List statement prior to exporting TracePro and RayViz software to a Sun Yat-Sen University laboratory in November 2023. Across all violations, Lamda committed 66 EAR breaches. While assessed a $2 million penalty, the full amount has been suspended for one year pending compliance with the settlement agreement; the penalty will be waived entirely if Lamda meets its obligations.
In a separate action, BIS renewed a Temporary Denial Order against URAL Airlines JSC for an additional one-year period, effective September 24, 2026. The airline violated export controls by operating controlled aircraft (ECCN 9A991.b designation) on flights into and out of Russia from Central Asian gateways—including Kyrgyzstan and Tajikistan—without required BIS authorization following Russia's March 2, 2022 invasion of Ukraine. BIS found evidence of continued violations through September 2025, including domestic Russian flights, prompting the renewal determination in the public interest to prevent imminent further violations. No monetary penalty was assessed in this action.
In a separate action, BIS renewed a Temporary Denial Order against URAL Airlines JSC for an additional one-year period, effective September 24, 2026. The airline violated export controls by operating controlled aircraft (ECCN 9A991.b designation) on flights into and out of Russia from Central Asian gateways—including Kyrgyzstan and Tajikistan—without required BIS authorization following Russia's March 2, 2022 invasion of Ukraine. BIS found evidence of continued violations through September 2025, including domestic Russian flights, prompting the renewal determination in the public interest to prevent imminent further violations. No monetary penalty was assessed in this action.
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