
export licenses and exported the related technical data to the PRC without
the required export licenses.
The Penalty: Lattice agreed to pay a $560,000 administrative penalty.
Mitigating Circumstance: Lattice voluntarily self-disclosed the violations
and fully cooperated with the investigation.
UNITED STATES PRINCIPAL PARTNER
OF INTEREST
The Census Bureau, BIS, and CBP always had a difficult
time enforcing export regulations on “routed transactions,”
in which U.S. manufacturers sold on an ex works basis and
had no functional or legal responsibility in the export pro-
cess. To counter this, the three government agencies came
up with the concept of USPPI. ...