On August 16, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) that it had reached a settlement agreement with Dynatex International (“Dynatex” or “the company”) – a California-based semiconductor company – where the company would pay a civil penalty of $469,060 for allegedly violating the Export Administration Regulations (EAR). In its Proposed Charging Letter (PCL), BIS charged Dynatex with only one violation of Conspiracy (15 C.F.R. § 764.2(d)), alleging that Dynatex conspired with “others known and unknown,” between December 14, 2015 and January 17, 2020, to export a “DTX-150 MDB scribe and break tool and associated...