DOJ Declines to Prosecute Bosch Under New Corporate Enforcement Policy
The DOJ declined to prosecute Bosch for export control violations under the new policy.
Why it matters: This marks the first use of the DOJ's Corporate Enforcement Policy, encouraging companies to self-disclose and cooperate. Legal teams should consider the policy's impact on compliance strategies and risk management.
- On June 17, 2026, DOJ declined to prosecute Bosch under its new Corporate Enforcement and Voluntary Self-Disclosure Policy introduced in March 2026.
- Between 2020-2024, Bosch subsidiaries exported over $70 million in sensor products/software to Huawei without required licenses.
- Bosch voluntarily self-disclosed, cooperated fully, and implemented remediation, including adding 66 compliance employees.
- Bosch agreed to disgorge $11.43 million in profits from unauthorized exports as part of resolution.
On June 17, 2026, the U.S. Department of Justice (DOJ) announced it declined to prosecute Robert Bosch GmbH for potential violations of the Export Control Reform Act (ECRA), applying its newly introduced Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), which was launched in March 2026 to unify enforcement approaches across DOJ divisions. This marks the first declination under this policy, setting a precedent for future corporate enforcement actions (DOJ press release).
Between September 2020 and September 2024, Bosch subsidiaries Bosch Sensortec GmbH and ETAS GmbH exported over $70 million worth of sensor products and software to Huawei Technologies, a company listed on the Entity List, without obtaining required licenses. Bosch voluntarily self-disclosed this misconduct, fully cooperated with the DOJ investigation, and took timely remediation measures, including expanding its trade compliance organization by adding 66 employees (DOJ statement).
As part of the resolution, Bosch agreed to disgorge $11,430,098 in profits derived from these unauthorized transactions. John A. Eisenberg, Assistant Attorney General for National Security, highlighted that this declination "reflects the clear benefits for companies that promptly disclose potential violations and fully assist in our investigations," and emphasized "the important role of transparency in safeguarding U.S. technology and national security."
The decision signals the DOJ's evolving approach to corporate enforcement, one that favors transparency, cooperation, and voluntary self-disclosure over immediate prosecution. Legal and compliance teams should evaluate how this policy might influence their internal strategies and risk assessments, especially in highly regulated sectors.
By the numbers:
- $70 million — value of unauthorized exports by Bosch subsidiaries to Huawei, 2020-2024
- $11.43 million — profits disgorged by Bosch as part of resolution
- 66 — number of compliance employees Bosch added during remediation