Rare Deemed Export Penalty

“Deemed export compliance is a top priority for the Bureau of Industry and Security,” a

BIS official said recently when announcing a $115,000 civil settlement with a California

company regarding five unlicensed disclosures of controlled manufacturing technology to

a Russian national working at its US facility. But you wouldn’t know that by the number

of BIS prosecutions or settlements involving deemed exports – I can’t remember the last

one – or by the government’s apparent leniency in settling with Intevac, Inc.

Deemed exports, as most readers of this blog know, are disclosures of US-origin

technology to non-US persons – foreign nationals not holding green cards – that are made

within the United States. (The concept flows from the regulatory definition of “export”,

which includes disclosures of US-origin technology made anywhere in the world – i.e.,

including within the US; and it captured the imaginations of regulators after a certain

A.Q. Khan carried all manner of nuclear secrets with him when he returned to his native

Pakistan – after working, quite legally, at the Dutch atomic energy R&D – to become the

“father of the Islamic bomb”.)


Thin Film

Intevac designs and manufactures innovative, high productivity, thin

film processing systems. Our production-proven platforms are designed

for high volume manufacturing of substrates with precise thin film


Today, we are the world’s leading supplier of magnetic media

processing systems, having shipped more than 220 manufacturing

systems to our HDD customers. More than 60% of the world’s

magnetic media is produced on Intevac systems.



Intevac Photonics is a technology leader in the development and

manufacture of compact, cost-effective, high-sensitivity digital-optical

sensors, cameras and systems for the defense industry, based on our

proprietary Electron Bombarded Active Pixel Sensor (EBAPS®) with

its advanced thin film technology. … We are the sole source provider

of integrated digital imaging systems for most U.S. military night

vision programs.

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