Deemed Export Regulations: Punishment
The EAR and ITAR subject violators to separate fines for violations, which – depending on criminal or civil liability – can run up to $1M or $250K per violation, respectively. How does this work?
Suppose that (without a license) you accidentally send design documents for controlled technology to a foreign client. It was a mistake, but you sent three different design documents for three different controlled technologies. Given that the disclosure was a mistake, the violation will likely only subject you to civil penalties. There were three violations, so in total, you could potentially be subject to $750K in fines for one mistaken disclosure.
Though compliance is complex – and often expensive – there are substantial penalties associated with non-compliance. You must make proper efforts to invest in compliance to ensure that you and your firm do not violate relevant deemed export regulations.