BIS reaches conditional settlement with suspended $2 million penalty for Lambda Research Corporation

WASHINGTON, September 29, 2026 — The Bureau of Industry and Security reached a conditional settlement with Lambda Research Corporation that would impose a $2 million civil penalty for 66 violations of the Export Administration Regulations.

Payment would be fully suspended for one year and then waived if the Massachusetts software company complies with the settlement and commits no further violations. Failure to meet the terms could activate the full penalty immediately.

Most of the violations arose from automatic software updates, which BIS treated as individual exports. Lambda transmitted 47 updates to Huawei Technologies Japan K.K. and seven to Shenzhen SiCarrier Technologies Co. Ltd. without required licenses after the companies were placed on the Entity List.

The conduct occurred from April 2021 through August 2025 and involved optical and illumination design software classified as EAR99. Lambda also admitted conduct underlying 11 charges of acting with knowledge of a violation involving Huawei Japan and one charge tied to an export involving an Unverified List party without obtaining the required statement.

Lambda disclosed the conduct to BIS in 2025. During the period covered by the charges, it had no written export compliance procedures and no personnel trained or specifically assigned to export compliance.

The settlement would require Lambda to designate at least two employees or officers to oversee export compliance and complete training within three months of an approving order. It also would require an internal compliance audit within nine months. Meeting those requirements would be a condition for Lambda’s export licenses, exceptions, permissions or privileges.

The agreement becomes binding only if the Assistant Secretary of Commerce for Export Enforcement, or a designee, approves it by issuing an order.