BIS reaches settlement agreement with Container Manufacturing Ltd over unlawful exports to Russia

25 August 2026

The US Bureau of Industry and Security has reached a $1,000,000 settlement agreement with Container Manufacturing Ltd, an Ohio-based company involved in the production of aluminium can tops – for 10 breaches of the Export Administration Regulations – Press Release.

Between March 2023 and March 2025, Container Manufacturing sold and exported designated EAR99 items with codes identified on the Russian and Belarusian Industry Sector Sanctions List (Supplement No. 4 to 15 C.F.R. Part 746) to an end user in Russia, both directly and through 2 third country distributors. The exports were not conducted in accordance with the license requirements set out in s. 746.8(a)(5) of the Regulations and were not otherwise authorised by BIS. The exported items included spare parts for aluminium metalworking tools worth $264,721 and were delivered to a Russian company whose corporate group is a supplier of ‘aluminium slugs’, which can be used to manufacture military equipment.

As a result of the exports, Container Manufacturing committed 8 breaches of Section 764.2(a) of the Regulations by ‘engaging in prohibited conduct’. It also committed 2 breaches of Section 764.2(e) of the Regulations by ‘acting with knowledge’ of the breaches. Evidence that it knew or should have known that the exports were prohibited includes the fact it named a third-party distributor as a ‘direct consumer’, and that it received payment by a third country distributor on behalf of the Russian company in March 2025.

Container Manufacturing has admitted all charges, fully co-operated with BIS, and has taken remedial measures to strengthen its compliance with the EAR, including by implementing additional end-user screening, transaction reviews, and improved recordkeeping. Under the settlement agreement it is due to pay $1,000,000 to the US Department of Commerce within 30 days of the date of the order (24 August 2026).

Compliance lessons:

• Respond to red flags proactively. Container Manufacturing was informed by its bank that the exports could be subject to legal restrictions, which refused to process wire payments in December 2024. It ignored these red flags.

• Clear transactions with appropriate due diligence where red flags arise. The Russian company had requested to alter shipping documents and the shipping route, and Container Manufacturing did not conduct adequate due diligence on the company before proceeding with the exports.

Learn more about BIS guidance on compliance, enforcement, and penalties on our US Guidance page.