BIS fines Teledyne FLIR $1 million over 19 export violations

WASHINGTON, Feb. 26, 2026 — The U.S. Commerce Department’s Bureau of Industry and Security has issued a final order imposing a $1 million civil penalty on Teledyne FLIR LLC and affiliates after the company admitted 19 violations of U.S. export control regulations involving thermal imaging cameras and related items.

The order says the violations spanned 2017 through 2024 and involved conduct by Teledyne FLIR, FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems Inc., doing business as Teledyne FLIR OEM. BIS said nine violations involved causing unauthorized exports from Sweden to China of items subject to the Export Administration Regulations after flawed de minimis calculations understated the value of controlled U.S.-origin camera kits and camera cores.

BIS also cited one evasion charge tied to FLIR’s 2018 collaboration with a Chinese drone manufacturer on the Zenmuse XT2 thermal camera. According to the order, the parties negotiated a “market collaboration fee” structure designed in part to push the value of controlled U.S. content below the 25% de minimis threshold, which BIS said was intended to avoid EAR licensing requirements.

A separate recordkeeping violation involved FLIR Optoelectronic in Shanghai, which BIS said failed to retain records required under a 2020 license governing demonstrations of a FLIR camera in China.

The remaining eight violations involved exports between June and December 2024 of thermal cameras to a Hong Kong address that BIS had placed on the Entity List under its new address-only listing framework. The address in Hong Kong, was identified by BIS as associated with significant transshipment of sensitive goods to Russia.

Under the order, Teledyne FLIR must pay the penalty within 30 days. BIS said failure to make full and timely payment could lead to a one-year denial of the company’s export privileges. The order took effect immediately and states that the proposed charging letter, settlement agreement and final order will be made public.