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BIS Readying More Penalties; Shifting Enforcement Resources to Iran, Officials Say

The Bureau of Industry and Security is working on multiple export control-related investigations that could soon lead to public penalties and criminal indictments, Commerce Department officials said last week. They also said BIS is doubling down on Iran-related enforcement as part of the Trump administration's renewed maximum pressure campaign against the country.

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Officials during the conference said the agency issued nearly $5 million in criminal penalties last year, an increase from the previous year, and suggested that trend will continue. “I'm willing to say we'll have some pretty interesting cases to share with you next year,” said one official, speaking on the condition of anonymity as part of a policy for career officials at the BIS annual update conference. “So stay tuned.”

BIS worked on cases last year that led to the arrest of more than 80 people suspected of violating the Export Administration Regulations, another official said. It also aided on more than 100 DOJ indictments, completed 1,440 end-use checks in 60 different countries, and carried out more than 3,000 outreach visits, liaisons and other “direct action activities that prevented the diversion of critical technologies,” the official said.

“A lot has changed since the last [BIS conference], but a lot has actually stayed the same,” the official said. “We're still moving forward at 100 miles an hour to counter the threats posed by nation state adversaries like China, Iran and Russia [to prevent them] from acquiring our most sensitive technologies.”

Multiple Commerce officials said BIS recently focused more of its enforcement resources on Iran after President Donald Trump issued a February memorandum ordering U.S. agencies to ramp up pressure (see 2502050020). One official said the agency is “surging” end-use checks around the world to specifically “focus on countering Iranian diversion,” while another official said “we shifted our focus and doubled down” on Iran-related work with other U.S. agencies in response to the memo.

BIS is in the middle of “a robust and continuous export control enforcement campaign to restrict the flow of sensitive technology and components to the Iranian regime,” the official said.

Another official added that this is “not a new problem set for us.” BIS has long had in place strict export controls against Iran and has increased those restrictions in recent years, including to try to prevent shipments of U.S.-origin items ending up in Iranian drones and later being shipped to Russia (see 2303220037). The Trump memo has made Iran even more of a priority, the official said.

“I think the renewed focus has allowed us to reorganize our resources, reach out to our interagency partners, and even integrate some of the older cooperations we've had with international partners to identify new trends and new procurement efforts that are supporting Iran,” the official said.

Commerce officials also said they’ve so far been continuing the BIS academic outreach program, an initiative launched under the Biden administration aimed at improving compliance at universities that face higher risks of illegal tech transfers (see 2303100021). BIS reached out to 20 universities when it began the effort in 2022, and an official said the program now includes 40 schools. This “reflects our increased commitment to enhancing research security and compliance among a broader range of academic institutions,” the official said.