Record Seagate enforcement a reminder it doesn’t matter if you think you’re right

Any compliance officer will tell you the best way to assess the risk of a certain matter is to think about it from a regulatory perspective.

“‘What would the Department of Justice think if we did this? Would this violate any laws or restrictions?’” If the answers to these questions aren’t clear, it’s often advised to err on the side of caution.

Seagate did not when it decided in 2020 to continue selling hard disk drives to Chinese telecommunications giant Huawei after the latter had certain export restrictions placed on it by the Commerce Department. The data storage company was fined $300 million—the largest stand-alone administrative penalty in the history of the Bureau of Industry and Security (BIS)—for this miscalculation.