BIS Issues Important Policy Changes On Trade Controls Violations Prevention And Enforcement

Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations. These statements – one at the National Association of College and University Attorneys (NACUA) 2022 Annual Conference – and the second at the 2022 BIS Update Conference on Export Controls and Policy (BIS Update) - messaged the Department's updated approach to supporting organizations such as universities in complying with trade controls, but also how the Bureau of Industry and Security (BIS) will handle violations going forward.

These announcements merit close review by university and corporate general counsel, chief compliance officers, and global trade leaders, and assessment of how the new policies and enforcement stance impact both the structure of existing compliance programs as well as the approach to potential violations.