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June 2025 EXPORT CONTROLS Commerce ShouldImprove WorkforcePlanning andInformation Sharing Highlights EXPORT CONTROLS Commerce Should Improve Workforce Planning andInformation Sharing Highlights ofGAO-25-107431, a report totheHonorable CharlesE. Schumer, MinorityLeader, U.S Senate What GAO Found Why GAO Did This Study Funding for Commerce’s Bureau of Industry and Security (BIS) grew by $97million and roughly doubled from fiscal years 2013 through 2024. During thistimeframe, the number of funded positions in BIS went from 403 to 585—anoverall increase of 182 positions. About $58 million (60 percent) of BIS’s 12-yearfunding increase was appropriated in fiscal years 2022 and 2023. BIS primarilyused these recent increases in two areas. First, to bolster implementation andenforcement of export controls in response to Russia’s 2022 invasion of Ukraine.Second, to create a new office focused on securing the U.S. information andcommunications technology and services supply chain. To address varied foreign policy andnational security concerns, the U.S.government has increasingly usedexport controls. For example, the U.S.has imposed export controls to restrictaccess to advanced semiconductorsthat could aid the People’s Republic ofChina in developing military systemspowered by artificial intelligence. BIS is primarily responsible forreviewing applications and issuinglicenses to exporters of dual-usetechnologies that could be used forboth civilian and military purposes.DOD, DOE, and State also play rolesin reviewing export licenseapplications. However, BIS does not have a long-term workforce plan to determine itsresource needs. Instead, BIS assesses its staffing needs on an annual basis aspart of the budget request process. BIS last conducted a bureau-wide workforceplanning effort in 2016. Comprehensive, long-term workforce planning would helpBIS leadership determine the size and composition of its workforce needed tomeet its expanding workload and better position it to reduce the risk of exportingsensitive, dual-use items to an adversary. BIS oversees an interagency export license review process which includesreviews by the Departments of Defense (DOD), Energy (DOE), and State.However, challenges to information-sharing and limited consultation compromisethe integrity of these reviews. For example, BIS does not provide the agenciesready access to all relevant information about export license applications, whichis housed in multiple classified and unclassified systems. Providing reviewingagencies with easy access to all information relevant to license applicationswould help ensure reviews are well informed. In addition, officials from reviewingagencies told us that BIS has sometimes removed agreed upon licenseconditions without consultation. According to BIS, it removed conditions that wereredundant or inconsistent with standard licensing provisions. Consulting withreviewing agencies prior to changing or removing conditions would help ensurethat licensing decisions fully reflect national security risks and other concerns. GAO was asked to review BIS’sresources and processes for exportlicensing. This report examines (1)BIS's resources from fiscal years 2013through 2024, (2) the extent to whichBIS has conducted workforce planning,and (3) the extent to which BIS sharesinformation and consults with reviewingagencies. GAO reviewed legislationand agency documents; interviewedCommerce, DOD, DOE, and Stateofficials; and analyzed agency funding,staffing, and workload data What GAO Recommends GAO is makingfour recommendations,including that Commerce conduct long-term workforce planning, providereviewing agencies access to allrelevant information, and consult withreviewing agencies prior to changinglicense conditions. Commerceconcurred with the recommendations. Contents Letter Background3BIS Used Recent Funding and Staffing Increases in Efforts toCounter Foreign Adversaries8BIS Has Not Conducted Comprehensive Long-term WorkforcePlanning Needed to Address Increases in Workload Demand12BIS Did Not Provide Reviewing Agencies Ready Access to AllRelevant Information or Consult with Them When RemovingLicense Conditions15Conclusions20Recommendations for Executive Action21Agency Comments21 Appendix IBureau of Industry and Security (BIS) Actions to Implement SelectedExport Control Reform Act Provisions23 Appendix IIObjectives, Scope, and Methodology27 Appendix IIIGAO Contact and Staff Acknowledgments30 Table 1: Department of Commerce’s Bureau of Industry andSecurity’s Selected Workload Measures, Fiscal Years2013 and 202314Table 2: Key Systems Used to Process and Share InformationAbout Export License Applications16 Figure 1: Key Steps in Interagency Review Process for theDepartment of Commerce’s Bureau of Industry andSecurity Export License Applications as of April 20254Figure 2: Simplified Organizational Chart for the Department ofCommerce’s Bureau of Industry and Security (BIS), as ofMarch 20256 Figure 3: Department