Bosch agreed to pay more than $43 million in penalties and disgorgement for illegally exporting products and software to Huawei in violation of U.S. export control laws, while simultaneously receiving the first declination issued under DOJ’s revised National Security Division Corporate Enforcement Policy. In this episode, Michael Volkov examines the enforcement action, the compliance failures that led Bosch to misunderstand and misapply the Foreign Direct Product Rule, the warning signs the company failed to recognize, and the lessons organizations can learn about export controls compliance, compliance staffing, escalation procedures, and risk management. The episode also highlights the significant benefits of voluntary self-disclosure, cooperation, and remediation in reducing criminal enforcement risk in today’s increasingly aggressive national security enforcement environment.