U.S. Releases 2024 Export Control Enforcement Report: High-Pressure Strategy Against 'Foreign Adversaries'

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) recently published the *Export Enforcement: 2024 Year in Review*, detailing enforcement actions taken over the past year targeting export control violations by China, Russia, and other “foreign adversaries” that could threaten U.S. national security. The report highlights key enforcement measures across various sectors, including sanctioning companies, strengthening protections for critical technologies, and building international cooperation networks. It underscores the U.S. government's aggressive stance in the field of export controls.

The report outlines a series of coordinated enforcement actions by the Department of Commerce, the Department of Justice, and the FBI to prevent China from acquiring advanced U.S. technology. Notable cases include:

- Semiconductor Export Controls:

- A Chinese national was convicted for illegally exporting semiconductor manufacturing equipment to China.

- GlobalFoundries was fined $500,000 for exporting semiconductor wafers worth $17 million to Chinese entities.

- Artificial Intelligence (AI) Cases:

- A Chinese citizen was arrested for allegedly stealing AI-related trade secrets from Google.

- Entity List Sanctions:

- 22 entities linked to China's quantum technology sector were added to the *Entity List*, restricting their access to U.S. technology and equipment.

The report highlights extensive interagency efforts to investigate and enforce measures against Russia's illegal procurement networks, focusing on nuclear weapons development, drone components, and electronic devices:

- A California resident was arrested for attempting to export hundreds of thousands of semiconductors to Russian military organizations.

- A company was fined $180,000 for exporting soldering materials used in electronic manufacturing to Russia.

- Several Russian nationals and collaborators were prosecuted or extradited for exporting sensitive microelectronic components to Russia's defense industry.

In 2024, the Department of Commerce expanded international enforcement cooperation, including:

- The Disruptive Technology Protection Network:

- Partnered with Japan and South Korea to share enforcement information and best practices.

- Collaboration with Allies:

- Hosted an annual export enforcement conference with Australia, Canada, New Zealand, and the United Kingdom, signing multiple bilateral agreements to enhance enforcement cooperation.

- G7 Joint Guidance:

- Issued the first-ever joint guidance with the G7 to prevent Russia from circumventing export controls.

With intensifying global competition in technology, the U.S. government imposed stricter export compliance requirements on universities and research institutions:

- Academic Outreach Initiative:

- Expanded the program from 29 universities in 2022 to 40 in 2024.

- Compliance Resources:

- Released a comprehensive guide for academic institutions to help identify risks and protect research integrity.

To address export control violations more effectively, the Department of Commerce introduced innovative measures:

- Updated Penalty Standards:

- Revised administrative penalty guidelines to reflect current enforcement practices.

- Entity List Additions:

- Added 16 addresses in Hong Kong and Turkey linked to shell companies facilitating the transshipment of over $130 million in high-priority items to Russia.

- Automated Screening System:

- Launched a new Commerce Screening System to fully automate foreign entity checks in export license applications.

The report reflects the U.S. government's targeted strategy in high-tech export controls, with a strong focus on curbing technology acquisition by China, Russia, and other countries of concern. The Department of Commerce emphasized plans to deepen collaboration with allied nations while leveraging advanced technologies to strengthen oversight of sensitive exports.