Virginia-based Wavelab pleaded guilty today to charges that it exported 2,400 microwave power amplifiers to China without the required licenses from the Bureau of Industry and Security (“BIS”). The company also agreed to forfeit the $85,000 it was paid for the amplifiers. Sentencing is scheduled for June 6, and the Court could impose additional fines.

The company’s website, which defaults to Chinese but is also available in English, lists 6 microwave amplifiers as its product line. Based on the spec sheets for these six products, it appears that they aren’t covered by ECCN 3A001.b.3 or 3A001.b.4, the two available classifications for microwave amplifiers. But the website also suggests that the company will custom produce microwave amplifiers for its customers, so it seems likely that such custom amplifiers were involved.

The company admitted in its plea agreement that it knew that the amplifier’s required licenses. Indeed, the ECCNs in question are relatively easy to apply and are based on the amplifier’s average output power, its frequencies of operation, its size and dimensions and its fractional bandwidth. (Fractional bandwidth is is the bandwidth of a device divided by its center frequency.) Although there are certainly ECCNs that pose difficulties in determining their applicability, these two are not among them.

An AP reporter that called the company for comment was told that everyone was “too busy” to talk and then hung up on.

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