Bosch: $36M for "ordinary" sensors and the Foreign Direct Product Rule

Part 1/3 · 9 min 45. The video is in French.

What the video covers

• 00:00 Introduction: the American jaw — foreign direct product, Entity List, enforcement
• 00:30 The Bosch case: a $36,184,680 civil penalty, 109 re-exports, sensors classified EAR99
• 06:00 How the trap closes: the Foreign Direct Product Rule in five steps
• 08:00 "Subject to the EAR": the five criteria of § 734.3(a)

Presentation by Matthew A. Bock, attorney (Bock Trade Law, Massachusetts), at the 16 September 2026 webinar of the Occitanie committee of the French Foreign Trade Advisors, where I spoke alongside him. The presentation is in French. It addresses US law and is general information, not legal advice. Published with the speaker's consent.

Other parts

• Part 2 — Applied Materials: $252.5M over a question of origin — de minimis and dual origin · 9 min 45
• Part 3 — Before 10 November: screen the customer, not just the product · 9 min 51

The four webinar chapters (Jan Holtzhäusser) →