As technology has become increasingly central to strategic competition with Russia and China, export controls have moved to the forefront of U.S. foreign policy on technology issues. Most notably, restricting Russia’s access to advanced technology through export controls is a key part of the U.S. response to Russia’s invasion of Ukraine, as U.S. government officials have repeatedly stated.
Unfortunately, nearly all the debate is focused on whether and when to apply export controls, not how to ensure that export controls are effectively administered and enforced after they are applied. The Bureau of Industry and Security (BIS) at the Department of Commerce oversees most export controls. BIS is increasingly confronting worldwide smuggling and export control evasion networks, especially those that are supported by Russia and China.