Winbond response
...Winbond declares that, when operating our company and business, we strictly comply with the law and regulations which include but are not limited to US Export Administration Regulations and Taiwan Regulations Governing Export and Import of Strategic High-Tech Commodities. We have a stringent internal control system, synchronizing with both “BIS Entity List (BIS)” and “the Internal Compliance Program (ICP)” by US and Taiwan governments respectively, to ensure that our products are not shipped to Russia or other restricted countries such as Iran, Cuba, DPRK, Iraq, and Sudan. Meanwhile, by stating in the contracts and agreements, Winbond requests our partners to comply with export control regulations, not to resale our products to the restricted areas, and to ensure our products will not be used in applications they were not designed for...
...[I]t is extremely challenging for Winbond to trace its products after sale. Recently, Winbond has received an email from Conflict Armament Research (CAR) seeking assistance in tracing the possible supply route of specific batches of Winbond products to Russia. After our internal investigation, it was found that the products used in military weapons were manufactured approximately five to ten years ago, and the same batch of products was shipped to ten different countries and dozens of customers, but none were shipped to Russia or restricted countries.
We regret to hear that our products may be used for military purposes without authorization, which is contrary to our philosophy of respecting human rights. Winbond reiterates that it will continue to monitor the supply chain with its business partners and fully cooperate with and assist the relevant authorities in their investigations...