
National Security Division Announces First Declination Under the Department-wide Corporate Enforcement Policy
US Department of Justice
The Justice Department announced today that it has declined the prosecution of Robert Bosch GmbH (Bosch), thereby resolving its investigation into an alleged scheme to send products and software manufactured with equipment that was the direct product of U.S. software or technology to an Entity-listed company in the People’s Republic of China (PRC). This decision was reached pursuant to Part I of the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), after also considering the factors set forth in the Department’s Principles of Federal Prosecution of Business Organizations. Bosch promptly disclosed the misconduct to the National Security Division (NSD), fully cooperated, and timely and appropriately remediated — which qualified them for a declination under the CEP, given that aggravating circumstances were absent Bosch has agreed to disgorge the $11,430,098 in profits it made as a result of the transactions at issue — a portion of which will be credited towards the $36,184,680 fine paid in a parallel civil action by the Department of Commerce.





