By then, SJS had already been handling GlobalFoundries chips as a third-party OSAT provider, so its involvement didn't trigger any "red flags" internally when GlobalFoundries' direct customer reengaged, shipping direct to SJS. It went unnoticed digitally in GlobalFoundries' Oracle Global Trade Management software module because the "ship to" party was incorrectly recorded as the direct customer. GlobalFoundries maintained a similar situation with another direct customer that employed SJS OSAT services, but had obtained the proper licenses in that scenario, lending credence to its narrative that the 74 shipments were done in error. While it may be an unfortunate mistake, it's a much less costly error than it could be. The maximum civil penalty allowed is $364,992 per violation or twice the value of the transaction. The latter amounts to $34.2 million in this scenario. Violators of the sanctions can also be denied export privileges.