In a morning webinar hosted today by the law firm Baker McKenzie and the International Compliance Professionals Association (ICPA), U.S. Department of Commerce, Bureau of Industry and Security Assistant Secretary Matthew Axelrod highlighted some of the prevailing trends in U.S. Export Enforcement for 2024. A few tidbits gleaned from his comments made today include:
- Russia and China will remain central priorities for enforcement of U.S. export controls for dual use commodities, software, and Technology. Axelrod specifically highlighted the U.S. government national security related concerns over products and technology that could provide other countries with technological advances in areas related to advanced quantum computing and hypersonic missile technology.
- The U.S. government intends to crack down on EAR controlled electronic components that are circumventing U.S. controls, either through clandestine procurement networks or transshipping through 3rd countries which, based on equipment found on the battlefield, are being used for production of drones, missiles, and other Russian military equipment.
- Additional regulation and guidance to enhance incentives for companies to come into BIS with voluntary disclosures is to be expected over the coming months.
- The recent trend towards interagency cooperation on enforcement is viewed by BIS as a positive development only to be enhanced over the coming years.
- Given ever increasing export control related risks in the changing global market, BIS says it is imperative for companies of all sizes to have an effective export compliance plan that is geared towards addressing today’s international business risks (i.e. China, Russia, Middle East). For small companies C-suite engagement is critical towards developing a top-down compliance culture.
- Axelrod recommends that companies take advantage of BIS resources including their offer to review and comment on your export compliance manual/plan. He also recommends that companies take advantage of and use export control officers both here in the USA and in foreign markets to help assess and review risks related to export transactions. In short don’t’ hesitate to contract BIS.
For further assistance with developing an effective export compliance manual/plan you can also contact TSI Global Consulting.