US reaches settlement agreement with Solventum over unlawful liqui-cel exports

8 April 2026

The US Bureau of Industry and Security (BIS) has reached a $1.6 million settlement with Solventum Corporation, a medical products company based in Minnesota, resolving two charges of aiding or abetting violations of the Export Administration Regulations (EAR).

The two charges relate to:

• Between December 2023 and January 2024, Solventum aided in the sale and transfer of 87 EAR99 Liqui-Cel Membrane Contactors to Semiconductor Manufacturing South China Corporation (SMIC South), an Entity List party, without the required BIS licence. BIS had partially suspended Solventum’s existing SMIC South licences in November 2023, and Solventum never sought a separate licence for the relevant purchase order despite knowing since November 2022 that the items were destined for SMIC South. Both the internal order request form and the purchase order contained the alias “SMSC”, an alias for SMIC South included on the Entity List. BIS found that Solventum had actual knowledge of this connection.

• In January 1, 2021, Solventum aided in the transfer of 9 Contactors to Ningbo Semiconductor International Corporation (NSI), also an Entity List party, without authorisation. NSI had been added to the Entity List in December 2020, prior to export, and no licence was obtained.

Solventum admitted the alleged conduct and agreed to pay a civil penalty of $1,600,000 to the US Department of Commerce within 45 days of the Order. Timely payment is a condition of Solventum’s continuing export privileges.

Compliance lessons:

• Alias screening must extend beyond primary Entity List names. All formally registered aliases must be captured across all transaction fields, including free-text item descriptions, project names, and internal order forms.

• A licence suspension requires an immediate audit of all open orders connected to the affected party, not just prospective shipments.

• Routed export transactions do not dilute the US Principal Party’s compliance responsibility and delegating fulfilment to a freight forwarder or intermediary does not transfer EAR obligations.

• Where an end user is identified in internal documentation, that identification constitutes knowledge for EAR purposes regardless of how the order is subsequently structured.