Contract analysis

I. SUMMARY HSI has identified three (3) shipments of HCA-9100 series analog-to-digital converter ("ADC") chipsets that may constitute violations of the Entity List restrictions set forth in 15 C.F.R. § 744.11. The HCA-9100 series chipsets are classified under Export Control Classification Number ("ECCN") 3A001, which covers certain electronic components, including monolithic integrated circuits designed for analog-to

II. DESCRIPTION OF THE TRANSACTIONS A. Shipment Details The following table summarizes the three shipments that are the subject of this VSD: The aggregate value of the three shipments is $1,197,000. The total number of units shipped across the three transactions is 1,380 units. All three shipments involved the same product — the HCA-9100-A3, a variant of the HCA-9100 series analog-to-digital converter chipset — and f

III. CIRCUMSTANCES OF THE VIOLATIONS A. Entity List Addition of Zhonghe Microelectronics Co., Ltd. On June 14, 2025, BIS published a final rule in the Federal Register (90 Fed. Reg. 42118) adding Zhonghe Microelectronics Co., Ltd. to the Entity List under the destination of China (People's Republic of). The final rule specified that a license is required for all items subject to the EAR when destined for Zhonghe, and

1. Sentinel Database Update Delay (Affecting All Three Shipments). Archipelago relies on a third-party restricted-party screening vendor, Sentinel Compliance Data Services Ltd. ("Sentinel"), for automated screening of all customers, consignees, and end users against applicable restricted party lists, including the BIS Entity List, the Specially Designated Nationals and blocked Persons List ("SDN List"), the Denied Pe

2. Absence of Re-Screening at Ship-Confirm Stage (Affecting Shipment No. 1 — June 27, 2025). The purchase order for the first post-listing shipment (Shipment No. 1) was entered into Archipelago's order management system on June 10, 2025 — four days before Zhonghe's addition to the Entity List. At the time of order entry, Archipelago's automated restricted-party screening, powered by Sentinel's database, performed a s

3. Character-Encoding and Name-Matching Mismatch (Affecting Shipments No. 2 and No. 3 — July 15 and August 3, 2025). The second and third post-listing shipments (Shipment No. 2 and Shipment No. 3) involved new purchase orders that were entered into Archipelago's order management system on July 8, 2025 and July 28, 2025, respectively. Both of these dates fall well after the June 26, 2025 Sentinel database update that

IV. DISCOVERY AND REMEDIAL ACTIONS A. Discovery of the Potential Violations The potential violations were discovered by Janet Liang, Trade Compliance Analyst at HSI, during a routine quarterly compliance review conducted in September 2025. Ms. Liang's review involved a reconciliation of recent shipments against current restricted party list data, including the most recent Entity List updates. During this reconciliati

V. RELATED GOVERNMENT INQUIRY The Company wishes to bring to OEE's attention a related government inquiry that is currently pending. The U.S. Department of Justice, National Security Division, Counterintelligence and Export Control Section ("DOJ NSD/CES"), has issued a voluntary request for information to HSI, dated October 9, 2025, bearing reference number NSD-CES-2025-04871. The DOJ inquiry encompasses the same thr

VI. PRELIMINARY ASSESSMENT OF KNOWLEDGE AND INTENT Based on the information gathered to date in the early stages of the Company's internal investigation, the Company believes that the three post-listing shipments to Zhonghe resulted from systemic process and technology failures, and not from intentional, willful, or knowing conduct on the part of any individual or entity. No evidence has been identified to date sugge

VII. SUPPLEMENTAL DISCLOSURE This initial VSD is intended to provide the Office of Export Enforcement with prompt notification of the potential violations, consistent with the timing expectations set forth in 15 C.F.R. § 764.5(c)(1) and the Company's commitment to transparency and full cooperation with BIS. The Company recognizes that this initial disclosure provides a preliminary account of the relevant facts and ci

VIII. CONTACT INFORMATION All communications regarding this Voluntary Self-Disclosure — including all correspondence, requests for information, subpoenas, and scheduling matters — should be directed to the undersigned counsel for the Company: Howard Quinn, Partner Calderwood & Harkness LLP 1301 K Street NW, Suite 1100 Washington, D.C. 20005 Telephone: (202) 555-0147 Facsimile: (202) 555-0199 Email: hquinn@calderwoodh