15 CFR §791.319

1. (a)If, after considering any written response to the pre-penalty notice and any relevant facts, including voluntary disclosure of a violation, BIS determines that there was a violation by the alleged violator named in the pre-penalty notice and that a civil monetary penalty is appropriate, BIS may issue a penalty notice to the violator containing a determination of the violation and the imposition of the monetary penalty.
2. (b)The issuance of the penalty notice shall constitute final agency action. The violator may seek judicial review of that final agency action in Federal district court.