PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT
CALDERWOOD & HARKNESS LLP One Liberty Plaza, 42nd Floor New York, NY 10006
MEMORANDUM
To: Vivienne St. Claire, Responsible Partner; Robert Adeyemi, Billing Partner
From: Claire Dempsey, Lead Associate; Audrey Zhou, Working Associate
Date: February 14, 2026
Re: Halcyon Semiconductor Aktiengesellschaft — Due Diligence Memorandum: Sanctions, Anti-Corruption, and Export Controls
Matter No.: 1032-00003
Confidentiality Note: This memorandum is prepared in connection with the prospective US initial public offering of Halcyon Semiconductor AG via a Level III American Depositary Receipt program and is protected by attorney-client privilege and the work product doctrine. This memorandum contains mental impressions, conclusions, opinions, and legal theories of attorneys at Calderwood & Harkness LLP and is not to be disclosed to any third party without the prior written consent of the responsible partner. Distribution is limited to the Calderwood & Harkness engagement team and authorized representatives of Halcyon Semiconductor AG, subject to the maintenance of applicable privilege protections.
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I. Executive Summary
This memorandum summarizes the findings of Calderwood & Harkness LLP's due diligence review of Halcyon Semiconductor Aktiengesellschaft ("Halcyon" or the "Company") with respect to the Company's compliance with United States, European Union, and other applicable sanctions regimes, anti-corruption laws, and export control regulations. This review has been conducted in connection with the proposed Registration Statement on Form F-1 (the "Registration Statement") to be filed with the US Securities and Exchange Commission (the "SEC") and the listing of American Depositary Shares ("ADSs"), each representing one ordinary share of Halcyon (nominal value €1.00 per share), on the Nasdaq Global Select Market under the proposed ticker symbol "HCYN" (the "Offering").
The scope of this review encompasses Halcyon and all of its material operating subsidiaries, specifically:
• Halcyon Semiconductor USA Inc., a Delaware corporation with its principal office at 2500 Augustine Drive, Suite 100, Santa Clara, California 95054 (the "US Subsidiary");
• Halcyon Power Solutions GmbH, a German limited liability company (Gesellschaft mit beschränkter Haftung) organized under the laws of the Federal Republic of Germany, with its principal office at Königsbrücker Straße 180, 01099 Dresden, Germany ("HPS Dresden");
• Halcyon Asia Pacific Pte. Ltd., a private limited company organized under the laws of Singapore, with its principal office at 1 Fusionopolis Walk, #07-01 Connexis South Tower, Singapore 138628 ("Halcyon APAC");
• Halcyon Shanghai Semiconductor Co., Ltd., a wholly foreign-owned enterprise (WFOE) organized under the laws of the People's Republic of China, with its registered address at No. 500 Zhangheng Road, Pudong New Area, Shanghai 201203, PRC ("Halcyon Shanghai"); and
• Halcyon Automotive Components s.r.o., a Czech limited liability company (společnost s ručením omezeným) organized under the laws of the Czech Republic, with its registered address at Technologický Park 2, 612 00 Brno, Czech Republic ("Halcyon Brno").
This due diligence review is of particular significance given several factors that elevate the Company's compliance risk profile. First, Halcyon is a semiconductor manufacturer specializing in advanced power semiconductor devices, including silicon carbide ("SiC") and gallium nitride ("GaN") chips designed for automotive, industrial, and renewable energy applications. These technologies are subject to heightened and evolving export control scrutiny in both the United States and the European Union, particularly with respect to shipments to the People's Republic of China and other destinations of concern. Second, the Company maintains active operations in the PRC through Halcyon Shanghai, a jurisdiction that has become the focus of escalating technology export restrictions and geopolitical tension. Third, the Company's global scale — with a workforce of approximately 8,400 employees across six countries and fiscal year 2025 ("FY2025") revenue of approximately €3.82 billion — creates a diverse set of compliance touchpoints across multiple regulatory regimes.
Key Conclusion. Subject to the detailed findings and recommendations set forth below, no material sanctions violations, anti-corruption violations, or export control violations have been identified during the course of this review that would constitute a bar to SEC registration, require qualification of any opinion to be delivered in connection with the Offering, or necessitate material adverse disclosure in the Registration Statement, provided that (a) the Company implements the enhanced compliance measures recommended in Section IX of this memorandum prior to or promptly following effectiveness of the Registration Statement, and (b) the prospectus included in the Registration Statement incorporates the risk factor disclosures recommended in Section X. Certain areas warrant continued monitoring and enhanced compliance measures, as detailed herein.
II. Scope and Methodology
A. Regulatory Frameworks Reviewed
In conducting this due diligence review, we analyzed Halcyon's compliance posture under the following regulatory frameworks:
US Sanctions Regulations:
• Regulations administered by the US Department of the Treasury, Office of Foreign Assets Control ("OFAC"), including all applicable Executive Orders, the Specially Designated Nationals and blocked Persons List (the "SDN List"), the Sectoral Sanctions Identifications List (the "SSI List"), the Non-SDN Chinese Military-Industrial Complex Companies List (the "NS-CMIC List"), and all other OFAC-administered sanctions lists comprising the OFAC Consolidated Sanctions List;
• Secondary sanctions provisions applicable to non-US persons, including those relating to Iran (Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, as amended), Russia (Executive Orders 13661, 13662, and 14024, among others), and other comprehensively sanctioned jurisdictions; and
• Entity List screening under 15 C.F.R. Part 744, Supplement No. 4 to Part 744, administered by the Bureau of Industry and Security ("BIS") of the US Department of Commerce.
EU Sanctions Regulations:
• EU Council Regulations implementing Common Foreign and Security Policy ("CFSP") sanctions, including, without limitation, Regulation (EU) No. 269/2014 (Ukraine-related sanctions — asset freezes), Regulation (EU) No. 833/2014 (restrictive measures in respect of Russia's actions destabilizing the situation in Ukraine, as amended through the fourteenth sanctions package), and all applicable EU Council Decisions and their implementing regulations; and
• Consolidated list of persons, groups, and entities subject to EU financial sanctions, as maintained by the European Commission.
Swiss Sanctions:
• Sanctions measures administered by the Swiss State Secretariat for Economic Affairs ("SECO"), relevant due to the Glenrock Assurance, Switzerland jurisdiction of Kestrel Capital Partners AG ("Kestrel"), a selling shareholder in the Offering. Swiss sanctions measures have been reviewed to the extent they mirror or deviate from EU sanctions in ways material to the Offering.
Anti-Corruption Laws:
• The US Foreign Corrupt Practices Act of 1977, as amended (the "FCPA"), including both the anti-bribery provisions (15 U.S.C. § 78dd-1 et seq.) and the books-and-records and internal controls provisions (15 U.S.C. §§ 78m(b)(2)(A) and (B));
• The UK Bribery Act 2010 (the "UKBA"), including Section 7 (failure of commercial organisations to prevent bribery);
• The German Criminal Code (Strafgesetzbuch, "StGB"), Sections 299 (bribery and corruption in commercial practice), 331 (acceptance of benefits by public officials), 332 (bribery of public officials), 333 (granting of benefits to public officials), 334 (bribery of public officials for the purpose of causing the official to act), and 335 (aggravated cases); and
• Applicable anti-corruption provisions of the laws of Singapore, the Czech Republic, and the PRC, to the extent relevant to Halcyon's subsidiary operations in those jurisdictions.
Export Control Regulations:
• The US Export Administration Regulations (the "EAR"), 15 C.F.R. Parts 730–774, administered by BIS at the US Department of Commerce, including the Commerce Control List ("CCL"), the Foreign Direct Product Rules ("FDPR"), and all applicable BIS rules targeting advanced semiconductor manufacturing equipment and technology;
• The International Traffic in Arms Regulations (the "ITAR"), 22 C.F.R. Parts 120–130, administered by the Directorate of Defense Trade Controls ("DDTC") at the US Department of State, including the United States Munitions List ("USML");
• The EU Dual-Use Regulation, Regulation (EU) 2021/821 of the European Parliament and of the Council of 20 May 2021, establishing a Union regime for the control of exports, brokering, technical assistance, transit, and transfer of dual-use items (recast), including Annex I thereto; and
• The PRC Export Control Law (effective December 1, 2020), the PRC Cybersecurity Law, the PRC Data Security Law, and the PRC Personal Information Protection Law, to the extent relevant to Halcyon Shanghai's operations and cross-border data transfers.
Listing and Disclosure Requirements:
• Applicable Nasdaq Stock Market LLC Listing Rules and related corporate governance requirements;
• SEC disclosure requirements under Regulation S-K, including Items 101, 105, and 303, as applied to risk factors and management's discussion and analysis relating to sanctions, export controls, and anti-corruption matters; and
• SEC Staff guidance regarding disclosure of contacts with countries or persons subject to US sanctions, including the Division of Corporation Finance's sample comment letters relating to sanctions and export controls.
B. Due Diligence Materials Reviewed
In connection with this review, we have examined the following categories of documents and materials, which were made available to us primarily through the virtual data room maintained by Halcyon (Data Room ID: HCY-IPO-VDR-001, administered by Crestline Solutions) and supplemented by direct production from Halcyon's German counsel, Bähr Stein Rechtsanwälte (Dr. Christoph Maurelban and Johanna Weiß):
1. Compliance Policies and Manuals. Halcyon's Global Compliance Policy (version 4.2, revised January 2023), Anti-Corruption and Anti-Bribery Policy (version 3.1, revised March 2023), Sanctions and Trade Controls Policy (version 2.4, revised June 2023), Gifts, Hospitality, and Entertainment Policy (version 2.0, adopted October 2021), Whistleblower Policy (version 1.3, adopted March 2020), and Third-Party Due Diligence Procedures Manual (version 2.1, revised September 2023).
2. Compliance Officer Reports. Annual compliance reports prepared by Halcyon's Chief Compliance Officer, Dr. Matthias Richter, for fiscal years 2023, 2024, and 2025, including compliance statistics, incident reports, training data, and compliance program assessment summaries.
3. Customer and Supplier Lists. Complete customer lists for all subsidiaries (approximately 2,300 direct customers globally), supplier lists for all subsidiaries (approximately 1,100 suppliers), and lists of all distributors and agents, as screened against the OFAC SDN List, OFAC Consolidated Sanctions List, BIS Entity List, BIS Denied Persons List, BIS Unverified List, BIS Military End-User List, and the EU Consolidated Financial Sanctions List.
4. Export Classification Records and License Applications. Internal product classification memoranda for Halcyon's principal SiC and GaN product lines, export license applications filed with BIS and the German Federal Office for Economic Affairs and Export Control (Bundesamt für Wirtschaft und Ausfuhrkontrolle, "BAFA"), and records of all export authorizations obtained and denied.
5. Anti-Corruption Training Records. Training attendance logs and completion certificates for anti-corruption training programs across all subsidiaries for FY2023, FY2024, and FY2025, including training content outlines and sign-off documentation.
6. Gift, Hospitality, and Entertainment Logs. Detailed logs of all gifts, hospitality, and entertainment expenditures above the applicable reporting threshold (€100 or local currency equivalent) for FY2023, FY2024, and FY2025, including pre-approval forms where required.
7. Third-Party Agent and Distributor Agreements. All current agreements with third-party sales agents, distributors, and intermediaries across all jurisdictions, with particular attention to APAC and PRC arrangements, including commission schedules, due diligence files, and anti-corruption representations and warranties.
8. Internal Audit Reports. Reports prepared by Halcyon's internal audit function relating to compliance matters for FY2023, FY2024, and FY2025, including audit scope, findings, management responses, and remediation tracking.
9. Management Interview Notes. Calderwood & Harkness conducted management interviews with the following individuals, and notes of such interviews have been reviewed and confirmed:
• Wilhelm Ostermann, General Counsel and Chefjustitiar, Halcyon Semiconductor AG (interviewed January 14, 2026 and January 28, 2026);
• Ingrid Baumann, Chief Operating Officer, Halcyon Semiconductor AG (interviewed January 16, 2026);
• Dr. Matthias Richter, Chief Compliance Officer, Halcyon Semiconductor AG (interviewed January 14, 2026 and February 3, 2026);
• Thomas Hartmann, VP Export Controls, Halcyon Semiconductor AG (interviewed January 21, 2026);
• David Chen, General Manager, Halcyon Shanghai Semiconductor Co., Ltd. (interviewed January 23, 2026, via video conference);
• Jennifer Koh, Compliance Manager, Halcyon Asia Pacific Pte. Ltd. (interviewed January 23, 2026, via video conference);
• Margaret O'Brien, General Counsel, Halcyon Semiconductor USA Inc. (interviewed January 15, 2026); and
• Peter Novák, Managing Director, Halcyon Automotive Components s.r.o. (interviewed January 24, 2026, via video conference).
10. Regulatory Correspondence. Correspondence with German regulatory authorities (BAFA), US regulatory authorities (BIS), and any communications with the SEC Division of Corporation Finance, OFAC, the US Department of Justice ("DOJ"), or the SEC Division of Enforcement relating to sanctions, export controls, or anti-corruption matters.
C. Coordination with Other Counsel
This due diligence review has been conducted in coordination with the following counsel, pursuant to the due diligence protocol agreed upon among the parties on December 18, 2025:
• Bähr Stein Rechtsanwälte (Dr. Christoph Maurelban, partner, and Johanna Weiß, senior associate), German counsel to Halcyon, headquartered in Munich, Germany. Bähr Stein has provided analysis of German law compliance matters, including German criminal code anti-corruption provisions, EU dual-use regulation compliance, and BAFA export control licensing matters. We have reviewed and relied upon Bähr Stein's memoranda dated January 30, 2026 (German Anti-Corruption Analysis) and February 5, 2026 (EU Dual-Use Regulation Analysis), subject to our independent assessment of US law implications.
• Prumvane Thornton LLP, German counsel to the underwriters, has conducted an independent verification review of certain compliance matters for purposes of the underwriters' due diligence defense under Section 11 of the Securities Act of 1933, as amended. We have coordinated with Prumvane Thornton to avoid duplication of effort and to ensure consistency of factual conclusions, while maintaining the independence of each counsel's analysis.
• Varen & Kessler LLP (Martin Ashford, partner, and Priya Ranganathan, counsel), US counsel to the underwriters. We have conducted a coordinated review with Varen & Kessler pursuant to the due diligence protocol, including joint management interviews and coordinated review of compliance materials. Our respective conclusions have been discussed and are substantially aligned with respect to the factual findings set forth herein, though each firm's legal analysis and recommendations are rendered independently.
The factual conclusions in this memorandum are based upon the materials reviewed and the interviews conducted as described above. We have not conducted an independent forensic investigation and have relied upon the completeness and accuracy of the materials provided by Halcyon and its advisors, subject to customary verification procedures.
III. OFAC Sanctions Compliance Analysis
A. Overview of OFAC Regime as Applied to Halcyon
The sanctions regulations administered by OFAC impose broad prohibitions on transactions involving sanctioned countries, governments, entities, and individuals. The scope and applicability of these prohibitions differ depending on whether a person is a "US person" for purposes of OFAC's primary sanctions or a non-US person potentially subject to secondary sanctions.
Primary Sanctions. OFAC's primary sanctions apply to "US persons," a term that generally includes (a) US citizens and permanent residents wherever located, (b) entities organized under the laws of the United States or any jurisdiction within the United States, including US territories, and (c) any person physically present in the United States. As a German Aktiengesellschaft headquartered in Munich, Halcyon itself is not a "US person" for purposes of OFAC primary sanctions. However, Halcyon's wholly owned US Subsidiary, Halcyon Semiconductor USA Inc. (EIN: 84-3927561), is a US person and is directly subject to the full scope of OFAC primary sanctions obligations.
US Nexus. Even for non-US persons, OFAC primary sanctions may be implicated where a transaction has a sufficient nexus to the United States. This includes transactions that (i) involve US dollar-denominated payments cleared through the US financial system, (ii) involve goods or technology of US origin, (iii) involve the US mail system or other US instrumentalities, or (iv) are conducted by or through US persons, including US financial institutions. Upon listing on the Nasdaq Global Select Market and raising capital in the United States — the Offering targets gross proceeds of approximately $900,000,000 — Halcyon's US touchpoints will increase substantially. The ADSs will be denominated in US dollars, cleared through The Depository Trust Company ("DTC"), and held by US institutional and retail investors. Dividends, if any, will flow through the US financial system. These factors create a broad and ongoing OFAC nexus for Halcyon's global operations.
Secondary Sanctions. Certain US sanctions programs impose secondary sanctions on non-US persons that engage in specified activities with sanctioned jurisdictions or persons, even absent a direct US nexus. Secondary sanctions may result in the loss of access to the US financial system, asset blocking, or other penalties. These provisions are particularly relevant to Halcyon as a non-US company with global operations.
Post-IPO Implications. Following the Offering, Halcyon will have additional compliance obligations arising from its status as a reporting company under the Securities Exchange Act of 1934, as amended (the "Exchange Act"). The SEC's Division of Corporation Finance has issued comment letters to foreign private issuers requesting detailed disclosure of any contacts with sanctioned countries or persons, and the SEC staff has heightened its scrutiny of such matters in the registration statement review process. Furthermore, Halcyon's access to the US capital markets will be contingent upon its ongoing ability to demonstrate compliance with US sanctions laws.
B. SDN and Restricted Party Screening
As a core component of this due diligence review, Calderwood & Harkness, in coordination with Halcyon's compliance department, conducted a comprehensive screening of Halcyon's customer base, supplier base, and third-party intermediary network against all applicable restricted party lists.
Scope of Screening. The screening covered:
• Halcyon's complete global customer base, comprising approximately 2,300 direct customers across all subsidiaries and business segments, including automotive OEMs and Tier 1 suppliers, industrial equipment manufacturers, and renewable energy system integrators;
• Halcyon's complete global supplier base, comprising approximately 1,100 suppliers of raw materials, equipment, components, and services; and
• All distributors, sales agents, and other third-party intermediaries engaged by any Halcyon entity.
Databases Screened. The screening was conducted against the following databases, using data current as of January 31, 2026:
• OFAC Specially Designated Nationals and blocked Persons List (SDN List);
• OFAC Consolidated Sanctions List (including the SSI List, NS-CMIC List, Foreign Sanctions Evaders List, and all other OFAC sub-lists);
• BIS Entity List (Supplement No. 4 to 15 C.F.R. Part 744);
• BIS Denied Persons List;
• BIS Unverified List;
• BIS Military End-User List (Supplement No. 7 to 15 C.F.R. Part 744); and
• EU Consolidated Financial Sanctions List (maintained by the European Commission).
Screening Methodology. Screening was conducted using Halcyon's compliance screening platform (Glenrock Solutions, integrated with Halcyon's Harborline Software ERP system), supplemented by manual verification by Calderwood & Harkness attorneys of all results flagged as potential matches or requiring further review. The screening platform utilizes fuzzy matching algorithms to account for transliteration variations, aliases, and name permutations. All potential matches were evaluated against the identifying information available for the relevant listed person or entity, including addresses, dates of birth, nationality, and other identifiers.
Results. No confirmed matches were identified against any person or entity on the OFAC SDN List, OFAC Consolidated Sanctions List, BIS Denied Persons List, or EU Consolidated Financial Sanctions List. No confirmed matches were identified against the BIS Entity List or BIS Military End-User List.
False Positives. The screening process generated thirty-seven (37) initial potential matches, all of which were investigated and resolved as false positives based on the following factors: (i) differences in registered addresses, jurisdictions of incorporation, or registration numbers; (ii) common name coincidences, particularly with respect to PRC entities sharing similar romanized names; and (iii) differences in industry sectors or business descriptions. Documentation of each false positive resolution, including the basis for determination, has been retained in the Calderwood & Harkness work files and is available for review upon request.
Recommendation. Upon listing, Halcyon should implement ongoing, real-time automated restricted party screening through its US Subsidiary as part of an enhanced post-IPO compliance program. Specifically, we recommend that all new customer onboarding, supplier qualification, and intermediary engagement processes include mandatory automated screening, with periodic rescreening of the existing customer and supplier base at least quarterly. The screening platform should be configured to include all OFAC, BIS, and EU sanctions lists, and to generate audit trails documenting screening results and any manual reviews.
C. Country-Level Sanctions Exposure
In addition to party-based screening, we conducted a country-level analysis of Halcyon's global sales, procurement, and operational footprint to identify any exposure to comprehensively sanctioned jurisdictions. Under OFAC regulations, US persons (and, in certain circumstances, non-US persons acting with a US nexus) are broadly prohibited from engaging in virtually all transactions involving Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk People's Republic, and Luhansk People's Republic regions of Ukraine.
Sales Analysis. We reviewed Halcyon's revenue data by country for FY2023, FY2024, and FY2025. No direct or indirect sales to customers located in Cuba, Iran, North Korea, Syria, or the Crimea/Donetsk/Luhansk regions were identified in any fiscal year under review. Halcyon's compliance policies explicitly prohibit sales to these jurisdictions, and the Company's ERP system includes country-based screening controls that block order entry for customers with shipping addresses in comprehensively sanctioned territories.
Supply Chain Analysis. We reviewed Halcyon's procurement records and supplier base to identify any sourcing from comprehensively sanctioned jurisdictions. No procurement of raw materials, components, equipment, or services from Cuba, Iran, North Korea, Syria, or the Crimea/Donetsk/Luhansk regions was identified.
PRC Operations. Halcyon Shanghai Semiconductor Co., Ltd. operates in the People's Republic of China, which is not subject to comprehensive OFAC sanctions. However, the PRC is subject to evolving sectoral restrictions under both US and EU regulatory frameworks, particularly with respect to advanced semiconductor technology. The PRC-specific compliance analysis is addressed in detail in Section VII below.
Other Jurisdictions of Concern. We also reviewed Halcyon's exposure to jurisdictions subject to targeted or sectoral OFAC sanctions programs, including Venezuela, Myanmar, and certain countries in sub-Saharan Africa. Halcyon does not conduct material business operations in any of these jurisdictions. Minor sales to customers in jurisdictions subject to limited sanctions programs (e.g., certain industrial customers in Turkey and the United Arab Emirates) were reviewed and determined not to implicate OFAC prohibitions.
D. Russia/Belarus Sanctions
Following the Russian Federation's invasion of Ukraine in February 2022 and the subsequent adoption of extensive multilateral sanctions by the European Union, the United States, the United Kingdom, Switzerland, and other jurisdictions, we conducted a detailed analysis of Halcyon's historical and current commercial relationships with Russia and Belarus.
Historical Sales. Prior to the imposition of comprehensive semiconductor-related export restrictions, Halcyon maintained limited commercial relationships with industrial customers in Russia. Based on our review of historical sales data, Halcyon's aggregate revenue from Russian customers in FY2021 was approximately €14.7 million, representing less than 0.5% of total revenue. Sales consisted primarily of SiC power modules for industrial motor drive applications, supplied to Russian industrial equipment manufacturers through Halcyon's distribution network.
Cessation of Sales. Halcyon ceased all direct shipments to Russian and Belarusian customers effective March 8, 2022, in response to the EU's adoption of restrictive measures targeting the Russian Federation. This cessation covered all product lines and was implemented across all Halcyon subsidiaries. The Company's Board of Directors (Vorstand) formally ratified this decision at its meeting of March 15, 2022, and the policy has been maintained without exception through the date of this memorandum.
Diversion Risk Analysis. Given the well-documented risk that sanctioned parties may attempt to procure restricted goods through intermediaries in third countries, we analyzed Halcyon's distribution arrangements in jurisdictions identified by OFAC and the EU as common transshipment points for Russia-bound goods, including Turkey, the United Arab Emirates, Kazakhstan, Armenia, Georgia, Kyrgyzstan, and Uzbekistan.
Our analysis included: (i) a review of Halcyon's customer onboarding and know-your-customer ("KYC") procedures for customers in these jurisdictions; (ii) an examination of order patterns and volume changes post-2022 to identify potential anomalies suggestive of diversion activity; and (iii) a review of Halcyon's contractual anti-diversion provisions.
Halcyon has implemented the following anti-diversion measures since July 2022: (a) contractual end-use and end-user certification requirements in all distribution agreements for markets identified as diversion risks; (b) anti-diversion clauses permitting Halcyon to terminate contracts and conduct audits upon suspicion of diversion; (c) enhanced due diligence for new customers in transshipment-risk jurisdictions, including beneficial ownership verification and end-user site visits where warranted; and (d) monitoring of order patterns through its compliance analytics platform.
Finding. No evidence of sanctions evasion or circumvention through third-country diversion was identified during the period under review. No Halcyon products were identified as having been re-exported or diverted to Russia or Belarus following the cessation of direct sales.
IV. EU Sanctions Compliance Analysis
A. EU Sanctions Framework
As a German Aktiengesellschaft with its registered office at Leopoldstraße 250, 80807 Munich, Germany, and listed on the Frankfurt Stock Exchange (FRA: HCY, Prime Standard segment, entered in the Commercial Register of the Local Court (Amtsgericht) Munich under registration number HRB 217458), Halcyon is a primary obligor under EU sanctions regulations. The EU sanctions framework is implemented through Council Regulations that have direct effect in all EU Member States, including the Federal Republic of Germany, and are binding on all natural and legal persons within the jurisdiction of the EU, as well as on EU nationals and entities wherever located.
The EU sanctions regime applicable to Halcyon encompasses both asset freeze measures (prohibiting making funds or economic resources available to designated persons or entities) and sectoral restrictions (prohibiting the export, sale, supply, or transfer of specified goods and technologies to certain countries or for certain end-uses). Of particular relevance to Halcyon are the EU's restrictive measures concerning Russia, which include prohibitions on the export of advanced technology goods — including semiconductor devices — to Russia or for use in Russia.
B. Compliance Findings
Halcyon maintains a dedicated EU sanctions compliance function within its legal department, reporting to Wilhelm Ostermann, General Counsel and Chefjustitiar. This function is responsible for implementing and maintaining the Company's EU sanctions compliance program, including restricted party screening, end-use monitoring, classification of products against EU sanctions control lists, and coordination with BAFA on export licensing matters.
We have reviewed the annual compliance reports prepared by Dr. Matthias Richter, Chief Compliance Officer, for FY2023, FY2024, and FY2025. These reports confirm that Halcyon has maintained ongoing screening of its customer and supplier base against the EU Consolidated Financial Sanctions List, and that the Company has implemented internal controls designed to ensure compliance with all applicable EU sanctions regulations.
Finding. No instances of EU sanctions violations were identified during the period under review.
Particular attention was devoted to Halcyon's compliance with the semiconductor-specific export restrictions contained in the EU's successive sanctions packages relating to Russia. Regulation (EU) No. 833/2014, as amended through the fourteenth package of sanctions adopted in June 2024, prohibits the export, sale, supply, or transfer of a broad range of goods and technologies — including advanced semiconductor devices — to Russia or for use in Russia. Annex VII to the regulation sets forth the list of controlled items, which includes semiconductor devices classified under certain Combined Nomenclature and Harmonized System codes.
Halcyon's SiC and GaN power semiconductor products fall within the scope of controlled items listed in Annex VII. The Company's power modules, discrete semiconductor devices, and integrated power management solutions for automotive and industrial applications are classified under customs codes that correspond to entries on the Annex VII control list. Accordingly, any export of these products to Russia or for use in Russia is prohibited.
Finding. Halcyon has confirmed the complete cessation of all sales of products to Russian customers and end-users since March 2022, as described in Section III.D above. This cessation encompasses all product lines, including those specifically controlled under Annex VII. No evidence of non-compliance with the EU's Russia-related semiconductor export restrictions was identified.
C. Swiss Sanctions (SECO)
Swiss sanctions regulations are relevant to this analysis due to the involvement of Kestrel Capital Partners AG, a Swiss-domiciled venture capital and growth equity firm (Bahnhofstrasse 36, 8001 Glenrock Assurance, Switzerland; Henrik Sørensen, Managing Partner), which is a significant pre-IPO shareholder of Halcyon and is expected to sell approximately 4,300,000 ordinary shares (in the form of ADSs) in the Offering as a selling shareholder.
Following Russia's invasion of Ukraine, Switzerland departed from its traditional position of strict neutrality and adopted sanctions measures largely mirroring those imposed by the EU. These measures are administered by SECO and are binding on all Swiss-domiciled persons and entities. We have reviewed the SECO sanctions regime as applicable to Kestrel's shareholding in Halcyon and to Halcyon's limited Swiss business activities (which consist solely of certain procurement arrangements with Swiss-based suppliers of specialty chemicals used in semiconductor fabrication).
Finding. No issues were identified with respect to Kestrel Capital Partners AG's shareholding in Halcyon or its participation as a selling shareholder in the Offering. Kestrel is not a sanctioned person or entity under any applicable sanctions regime, and its sale of shares in the Offering does not implicate any SECO, OFAC, or EU sanctions prohibitions. Halcyon's limited Swiss business activities do not raise sanctions concerns.
V. Anti-Corruption Compliance Analysis
A. FCPA Analysis
1. Applicability Post-Listing
The FCPA comprises two principal sets of provisions: (a) the anti-bribery provisions, which prohibit the payment of bribes to foreign government officials to obtain or retain business, and (b) the books-and-records and internal accounting controls provisions, which require issuers to maintain accurate books and records and to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that transactions are properly authorized, recorded, and reported.
Upon the effectiveness of the Registration Statement and the listing of ADSs on the Nasdaq Global Select Market, Halcyon will become an "issuer" within the meaning of Section 30A of the Exchange Act. As an issuer, Halcyon will be subject to both the anti-bribery provisions (15 U.S.C. § 78dd-1) and the books-and-records and internal controls provisions (15 U.S.C. §§ 78m(b)(2)(A) and (B)). The anti-bribery provisions will apply to Halcyon's officers, directors, employees, agents, and shareholders acting on the Company's behalf worldwide. The books-and-records and internal controls provisions will require Halcyon to maintain accurate books and records in reasonable detail and to maintain internal accounting controls that provide reasonable assurances that transactions are authorized, properly recorded, and conducted in accordance with management's authorization.
Prior to listing, Halcyon is nonetheless potentially subject to FCPA jurisdiction through multiple avenues: (i) the US Subsidiary, Halcyon Semiconductor USA Inc., is a "domestic concern" under 15 U.S.C. § 78dd-2 and is independently subject to the FCPA's anti-bribery provisions; (ii) any acts in furtherance of corrupt payments that utilize US instrumentalities — including US mail, wire transfers routed through US correspondent banks, or other interstate or international commerce involving the United States — may establish territorial jurisdiction under 15 U.S.C. § 78dd-3; and (iii) the DOJ has taken the position that the mere use of the US financial system to process a payment creates a sufficient jurisdictional basis for FCPA enforcement.
2. Corruption Risk Assessment
We have conducted a corruption risk assessment evaluating the principal areas of FCPA exposure across Halcyon's global operations.
Government Customer Exposure. Halcyon's customer base includes a number of state-owned enterprises ("SOEs") and government-affiliated entities, particularly in the automotive, industrial, and renewable energy sectors. The officers and employees of SOEs are considered "foreign officials" for purposes of the FCPA's anti-bribery provisions, and payments, gifts, or benefits provided to such persons to obtain or retain business may constitute violations. Areas of heightened risk include:
• PRC Operations: Halcyon Shanghai serves customers in the PRC automotive sector, which includes several SOEs and SOE subsidiaries, including major automotive groups with partial or full state ownership. Approximately 23% of Halcyon Shanghai's FY2025 revenue (approximately €163 million of €709 million in total PRC revenue) was derived from customers that qualify as SOEs or entities with significant government ownership stakes. The involvement of SOEs in procurement decisions creates inherent FCPA risk.
• APAC Operations: Halcyon APAC serves customers across Southeast Asia, India, South Korea, Japan, and Australia. Certain customers in the renewable energy and industrial sectors in Southeast Asian markets (including Indonesia, Vietnam, and Thailand) are government-affiliated or maintain close relationships with government decision-makers. Revenue from government-affiliated customers in APAC (excluding PRC) represented approximately 8% of Halcyon APAC's FY2025 revenue.
• European and US Operations: FCPA risk from government customer exposure in Europe and the United States is comparatively lower, though Halcyon supplies components to certain partially state-owned European automotive manufacturers and receives government grants and subsidies for its Dresden fabrication expansion, which creates indirect government touchpoints.
Third-Party Intermediaries. The use of third-party agents, distributors, consultants, and other intermediaries is a well-established area of FCPA enforcement risk, as such intermediaries may serve as conduits for corrupt payments. We reviewed all current third-party agent and distributor agreements across all Halcyon subsidiaries, with particular focus on:
• Commission structures: We analyzed commission rates paid to third-party agents and distributors to identify any arrangements with commission rates that deviate significantly from market norms or that include unusual payment terms. No anomalous commission structures were identified. Commission rates ranged from 2.5% to 7.0% of net sales, which is consistent with industry benchmarks for the semiconductor distribution sector.
• Due diligence documentation: We reviewed Halcyon's due diligence files for third-party agents and distributors, including background check reports, anti-corruption questionnaires, and compliance certifications. Due diligence files were generally complete for intermediaries onboarded after the adoption of Halcyon's enhanced Third-Party Due Diligence Procedures Manual in September 2023. For intermediaries onboarded prior to that date, due diligence documentation varied in completeness, and we recommend that Halcyon conduct retroactive due diligence on all legacy intermediary relationships (see Section IX.B below).
• Contractual anti-corruption representations: All agent and distributor agreements executed after March 2023 include anti-corruption representations and warranties, compliance certification requirements, audit rights, and termination provisions in the event of anti-corruption violations. Agreements executed prior to that date contain less robust anti-corruption language and should be amended or replaced.
Government Permits and Inspections. Halcyon's semiconductor fabrication facilities in Munich, Dresden (Fab 2, operational; Fab 3, under construction), and Brno require a range of environmental, health and safety, construction, and manufacturing permits from governmental authorities. The permitting process creates potential touchpoints for facilitation payments or improper inducements to government officials. We note that while the FCPA's anti-bribery provisions contain a narrow exception for "facilitating payments" made to expedite routine governmental action, (i) this exception has been interpreted very narrowly by US enforcement authorities, (ii) the UKBA does not recognize any facilitating payment exception, and (iii) German law prohibits such payments. No evidence of facilitation payments, improper inducements, or other corrupt payments in connection with permitting or inspection processes was identified.
3. Compliance Program Assessment
Halcyon has maintained a written anti-corruption policy since 2016. The current version (version 3.1) was adopted in March 2023 and reflects updates to address evolving regulatory guidance and enforcement trends. The policy covers all Halcyon employees worldwide and extends to agents, consultants, and other third parties acting on Halcyon's behalf. The policy expressly prohibits bribery of government officials and commercial bribery, sets forth the Company's commitment to compliance with the FCPA, the UKBA, and applicable local anti-corruption laws, and describes prohibited conduct, reporting obligations, and disciplinary consequences.
Training. Halcyon provides annual anti-corruption training to all employees in management, sales, procurement, and government-facing roles. Training is delivered through a combination of live instructor-led sessions (for senior management and high-risk roles) and online e-learning modules (for the broader employee population). We reviewed training completion records for FY2024 and FY2025. In FY2024, the training completion rate was 96.2% for designated employees across all subsidiaries. In FY2025, the completion rate was 97.1%. Employees who failed to complete training within the designated period received escalation notices, and all outstanding training was completed within thirty (30) days of the escalation.
Gifts, Hospitality, and Entertainment. Halcyon's Gifts, Hospitality, and Entertainment Policy establishes monetary thresholds (€200 per occurrence for gifts; €500 per occurrence for hospitality and entertainment) above which pre-approval from the compliance department is required. All gifts, hospitality, and entertainment above the reporting threshold of €100 must be logged in the Company's compliance reporting system. We reviewed the logs for FY2023, FY2024, and FY2025. Expenditures were generally consistent with legitimate business purposes, and pre-approval documentation was present for expenditures above the applicable threshold. No expenditures were identified that raised concerns regarding improper benefits to government officials.
Third-Party Due Diligence. As noted above, Halcyon's Third-Party Due Diligence Procedures Manual (version 2.1, revised September 2023) sets forth procedures for risk assessment, background screening, anti-corruption questionnaires, and ongoing monitoring of agents and distributors. The procedures assign risk ratings (low, medium, and high) based on factors including the intermediary's jurisdiction, the nature of its activities, its proximity to government customers, and the results of background screening. High-risk intermediaries are subject to enhanced due diligence, including in-person interviews and periodic re-certification.
No Investigations or Enforcement Actions. Based on our review of all available records, management interviews, and representations provided by Halcyon's General Counsel, no FCPA investigations, SEC or DOJ enforcement actions, voluntary self-disclosures, or government inquiries relating to anti-corruption matters involving Halcyon or any of its subsidiaries, officers, or directors have been initiated, are pending, or, to the Company's knowledge, are threatened.
4. Findings and Recommendations
Finding. No evidence of bribery, corrupt payments, or improper benefits provided to foreign government officials was identified during the course of this review. Halcyon's existing anti-corruption compliance program is generally appropriate for a multinational corporation of its size and industry, but will require enhancement to meet the expectations of US enforcement authorities and the heightened obligations of a US-listed issuer.
Recommendations. Prior to or promptly following the effectiveness of the Registration Statement and listing on Nasdaq, Halcyon should implement the following enhancements to its anti-corruption compliance program:
(a) Dedicated FCPA/Sanctions Compliance Officer: Appoint or designate a compliance officer with specific responsibility for FCPA compliance, OFAC sanctions compliance, and coordination of the Company's global anti-corruption and sanctions compliance program. This role should have a direct reporting line to the Audit Committee of the Supervisory Board (Aufsichtsrat) and should be empowered with sufficient resources and authority.
(b) Enhanced Due Diligence for PRC and APAC Intermediaries: Conduct enhanced due diligence, including retroactive due diligence on legacy intermediary relationships, for all third-party agents and distributors operating in the PRC and APAC jurisdictions. This should include updated background screening, in-person or video conference interviews, and re-execution of anti-corruption compliance certifications.
(c) Books-and-Records and Internal Controls: Upgrade the Company's internal accounting controls and books-and-records practices to satisfy the requirements of Exchange Act Sections 13(b)(2)(A) and (B). This includes implementing controls to ensure that all payments to third parties are accurately recorded and that no off-books accounts, unrecorded funds, or payments without adequate documentation exist.
(d) Code of Business Conduct and Ethics: The Code of Business Conduct and Ethics being drafted for Nasdaq Listing Rule 5610 compliance should include robust anti-corruption provisions, including specific reference to the FCPA, UKBA, and applicable local anti-corruption laws, and should address the prohibition on facilitation payments.
B. UK Bribery Act 2010 Analysis
The UKBA establishes several offences relating to bribery, including active bribery (Section 1), passive bribery (Section 2), bribery of foreign public officials (Section 6), and failure of a commercial organisation to prevent bribery by associated persons (Section 7). Section 7 is of particular relevance to Halcyon, as it imposes strict liability on commercial organisations that fail to prevent bribery by persons associated with them, unless the organisation can demonstrate that it had "adequate procedures" in place designed to prevent such conduct.
Applicability. The UKBA applies to any commercial organisation that "carries on a business, or part of a business" in the United Kingdom, regardless of where the organisation is incorporated or where the bribery occurs. Halcyon does not maintain a UK subsidiary, branch office, or permanent establishment. However, the Company has UK-based customers representing approximately £42 million in FY2025 revenue, utilizes UK-based service providers including Blackmere & Whitfield LLP (public relations advisory) and Clearwater D&O Insurance Brokers Ltd. (directors' and officers' liability insurance), and has employees who travel to the United Kingdom for business purposes. The Serious Fraud Office has taken a broad view of the "carries on a business" nexus, and we cannot exclude the possibility that Halcyon's UK-related activities could be sufficient to establish UKBA jurisdiction.
Finding. Halcyon's existing compliance program substantially addresses the "adequate procedures" requirements set forth in the Ministry of Justice's Guidance published under Section 9 of the UKBA. The six guiding principles — proportionality, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review — are each reflected in Halcyon's policies and procedures as reviewed. No UKBA investigations, proceedings, or reportable incidents have been identified.
Recommendation. We recommend that Halcyon formally document its UKBA "adequate procedures" assessment, including a written memorandum to the file confirming the evaluation of each of the six guiding principles against Halcyon's compliance program. This documentation would strengthen the Company's defense in the event of any future UKBA inquiry. Additionally, the updated compliance program should include UKBA-specific provisions, including express prohibition of facilitation payments and coverage of commercial bribery (which, unlike the FCPA, is a standalone offence under the UKBA).
C. German Anti-Corruption Laws
As a German Aktiengesellschaft, Halcyon is subject to the anti-corruption provisions of the German Criminal Code (Strafgesetzbuch, "StGB"), including:
• Section 299 StGB — Bribery and corruption in commercial practice (Bestechlichkeit und Bestechung im geschäftlichen Verkehr): prohibits the offering, promising, or granting of advantages to employees or agents of a business enterprise in exchange for preferential treatment in the procurement of goods or services;
• Sections 331–335 StGB — Offences relating to the bribery of public officials (Bestechungsdelikte im Amt): prohibit the offering, promising, or granting of advantages to public officials (Amtsträger) in connection with their official duties.
Bähr Stein Rechtsanwälte (Dr. Christoph Maurelban) has provided a separate analysis of Halcyon's compliance with German anti-corruption laws, dated January 30, 2026. In that analysis, Bähr Stein confirms that:
(i) No criminal investigations (Ermittlungsverfahren) or proceedings (Strafverfahren) relating to bribery, corruption, or related offences involving Halcyon or any of its current or former officers and directors (Vorstands- und Aufsichtsratsmitglieder) are pending before any German court or prosecutorial authority;
(ii) No such investigations or proceedings are, to the knowledge of Halcyon's General Counsel, threatened; and
(iii) Halcyon's compliance program, including its written anti-corruption policy, training program, and third-party due diligence procedures, is consistent with the expectations of German prosecutors and courts with respect to organisational compliance measures under Section 130 of the German Administrative Offences Act (Ordnungswidrigkeitengesetz, "OWiG"), which imposes liability on organisations that fail to implement adequate supervisory measures to prevent criminal offences.
Finding. No issues relating to German anti-corruption laws were identified.
VI. Export Control Analysis — US Regulations (EAR/ITAR)
A. Export Administration Regulations (EAR)
1. Overview and Applicability
The Export Administration Regulations, promulgated at 15 C.F.R. Parts 730–774 and administered by the Bureau of Industry and Security at the US Department of Commerce, regulate the export, reexport, and transfer (in-country) of items that are "subject to the EAR." An item is subject to the EAR if it is: (a) physically located in the United States; (b) of US origin (i.e., manufactured or produced in the United States); (c) a foreign-made item that incorporates more than a de minimis amount of controlled US-origin content (the de minimis threshold is generally 25% of the total value of the item, but is reduced to 10% for items destined to certain countries and end-users); or (d) the "direct product" of certain US-origin technology or software, as defined by the Foreign Direct Product Rules under EAR § 736.2(b)(3) and related provisions.
The EAR is of significant relevance to Halcyon's operations for several reasons. First, Halcyon Semiconductor USA Inc. exports and reexports US-origin items in the ordinary course of its business, including technical data, software, and certain physical components. Second, Halcyon's German and Czech fabrication facilities utilize US-origin manufacturing equipment and incorporate US-origin process technology in the fabrication of semiconductor devices, potentially rendering certain foreign-produced items subject to the EAR under the de minimis and direct product rules. Third, the BIS has implemented a series of targeted rules restricting semiconductor-related exports to the PRC and certain other destinations, which have direct implications for Halcyon's product shipments and technology transfers.
2. Product Classification Analysis
Under the EAR, all items subject to the EAR are either (a) classified under a specific Export Control Classification Number ("ECCN") on the Commerce Control List ("CCL"), Supplement No. 1 to 15 C.F.R. Part 774, or (b) designated as "EAR99," meaning they are subject to the EAR but not specifically listed on the CCL and are generally eligible for export to most destinations without an individual license (subject to end-use and end-user restrictions and certain embargoed destinations).
We have reviewed the internal product classification memoranda prepared by Halcyon's export control team, under the supervision of Thomas Hartmann, VP Export Controls, for Halcyon's principal SiC and GaN product lines.
SiC Power Semiconductor Devices. Halcyon's SiC product portfolio includes SiC MOSFET discrete devices, SiC power modules for automotive traction inverters, and SiC Schottky barrier diodes for industrial power conversion. Classification analysis indicates:
• ECCN 3A001 ("Electronic components") — ECCN 3A001 covers a range of electronic components, including certain semiconductor devices designed to operate at specified performance parameters (e.g., voltage ratings, current handling, operating temperature ranges). However, the specific control parameters in ECCN 3A001 are primarily directed at high-frequency, high-speed switching, or radiation-hardened devices with military or strategic applications. Halcyon's commercial SiC power devices, designed for automotive and industrial power conversion at relatively low switching frequencies (typically under 500 kHz), generally do not meet the performance thresholds triggering ECCN 3A001 classification.
• ECCN 3A991 ("Electronic devices and components not controlled by 3A001") — This ECCN captures lower-controlled electronic components that do not meet the performance thresholds of ECCN 3A001 but are nonetheless controlled for anti-terrorism ("AT") reasons. Certain Halcyon SiC products with higher voltage ratings (1,700V and above) may be classifiable under ECCN 3A991. Items classified under ECCN 3A991 are generally eligible for export to most destinations under License Exception provisions or without an individual license, though AT-only controlled items remain restricted to certain comprehensively embargoed destinations.
• EAR99 — The majority of Halcyon's high-volume commercial SiC products (650V and 1,200V rated SiC MOSFETs and modules for automotive traction inverters and industrial motor drives) are classified as EAR99 based on their specifications.
GaN Power Semiconductor Devices. Halcyon's GaN product portfolio includes enhancement-mode GaN HEMTs (high electron mobility transistors) for high-efficiency power conversion in server power supplies, renewable energy inverters, and fast-charging applications. Classification analysis indicates:
• ECCN 3A001.b — This sub-entry controls semiconductor devices "designed for operation at frequencies exceeding" specified thresholds, with additional parameters relating to power output and frequency. Certain of Halcyon's GaN devices designed for high-frequency power conversion applications (e.g., GaN HEMTs rated for operation at switching frequencies above 1 MHz with peak power outputs exceeding specified levels) may potentially be classifiable under ECCN 3A001.b, depending on the precise specifications and intended applications.
• EAR99 — The majority of Halcyon's commercial GaN power devices, designed for applications below the ECCN 3A001.b performance thresholds, are classified as EAR99.
• Advanced Research-Stage GaN Devices — Halcyon's R&D pipeline includes certain next-generation GaN-on-SiC devices with parameters that may exceed ECCN 3A001 control thresholds, including devices with military-relevant frequency and power handling characteristics. These products are not yet in commercial production and are in the early stages of development. If and when these products reach commercialization, a formal classification determination should be obtained from BIS (through a commodity classification request) or from Halcyon's export control team, and appropriate export control measures should be implemented.
Finding. Based on our review of Halcyon's product classification memoranda and discussions with Thomas Hartmann, the substantial majority of Halcyon's current commercial power semiconductor products — representing in excess of 95% of FY2025 revenue — are classified as EAR99 or ECCN 3A991 and are generally eligible for export to most destinations without an individual BIS license, subject to end-use and end-user restrictions. Certain advanced GaN devices, if and when commercialized, may require further classification analysis and potentially individual export licenses for certain destinations.
3. De Minimis and Direct Product Rule Analysis
The applicability of the EAR to Halcyon's foreign-manufactured products turns in significant part on the de minimis rule and the Foreign Direct Product Rules. These provisions are technically complex and are the subject of ongoing regulatory evolution, particularly with respect to semiconductor manufacturing.
*De Minimis* Rule. Under EAR § 734.4, a foreign-made item is subject to the EAR if it incorporates US-origin controlled content (i.e., content classified on the CCL with an ECCN other than EAR99) in excess of the applicable de minimis percentage. The general de minimis threshold is 25% of the total value of the foreign-made item. For items destined to Cuba, Iran, North Korea, and Syria, the threshold is reduced to 10%. The de minimis calculation considers only the value of US-origin controlled components, not EAR99 components.
Halcyon's fabrication facilities in Dresden and Brno utilize certain US-origin manufacturing equipment (including photolithography tools, etching systems, and metrology equipment), as well as US-origin process chemicals and consumables. However, the US-origin content of the finished semiconductor devices manufactured at these facilities consists primarily of EAR99 components and materials that do not carry ECCN classifications. Our preliminary analysis, based on information provided by Halcyon's operations team, indicates that the US-origin controlled content of Halcyon's German- and Czech-manufactured products is below the 25% de minimis threshold. We recommend that Halcyon conduct a formal de minimis calculation for its principal product families, documented in writing and maintained in the Company's compliance files.
Foreign Direct Product Rules. The FDPR, codified at EAR § 736.2(b)(3) and related provisions in Supplement No. 7 to Part 746, extend the jurisdictional reach of the EAR to foreign-made items that are the "direct product" of US-origin "technology" or "software" that is specified in certain ECCN categories. The FDPR have been significantly expanded in recent years through a series of BIS rulemakings targeting, among other things, advanced semiconductor manufacturing. Key FDPR variants include:
• Entity List FDPR