DOJ’s NSD Announces First Declination Under New CEP
On June 17, 2026, the U.S. Department of Justice (“DOJ” or
“Department”) National Security Division (“NSD”) issued a press
release announcing its first declination under the new Department-wide
Corporate Enforcement and Voluntary Self-Disclosure Policy (the
“CEP”). The CEP, announced on March 10, 2026, is an explicit attempt to
harmonize prior corporate enforcement and self-disclosure standards across the
DOJ and the U.S. Attorneys’ Offices.
The Department declined to prosecute Robert Bosch GmbH
(“Bosch”), resolving its investigation into an alleged scheme to send products
and software made with equipment that was derived from U.S. software or
technology to an Entity-listed company in the People’s Republic of China
(“PRC”). According to NSD, its investigation uncovered evidence that, from
September 2020 to September 2024, two of Bosch’s non-U.S. subsidiaries
re-exported more than $70 million of foreign-produced Micro-Electro-Mechanical
Systems (“MEMS”) sensor products and software to Huawei Technologies Co., Ltd.
and its Entity-listed affiliates without the authorization required from the
U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”).