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BIS Imposes Record Penalty on Applied Materials, Rejects Customs’ Substantial Transformation Test, but Offers No Clear Standard for Foreign-Origin Determinations
Kay C. Georgi, Megan Barnhill, James Kim*, Christopher H. Skinner, Sylvia G. Costelloe, Derek Ha

On February 11, the US Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement agreement and $252 million civil penalty against California-based Applied Materials Inc. and its subsidiary Applied Materials Korea, Ltd.

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