Energy Workforce & Technology Council recently participated in a roundtable discussion with Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (BIS). Axelrod met with business leaders from the energy industry through a roundtable hosted by the Houston District Export Council.
Representatives from Member Companies Crane Worldwide Logistics, Halliburton and Schlumberger, as well as Energy Workforce Director Government Affairs, Maria Suarez, participated in a discussion focused on the BIS export enforcement approach, new controls on oil refinery equipment, and building partnerships with the BIS office.
Axelrod discussed how the BIS Export Enforcement office focuses on ensuring that technology produced in the United States does not make its way to malicious state actors and what enforcement mechanisms are currently in place. He stressed that companies need to focus on these risks the same way they did when the Foreign Corrupt Practices Act was enacted.
With the current Russian invasion of Ukraine, the BIS office has taken significant steps on the enforcement side. These include the four rules imposed from February 24 through March 11 that curtail exports to Russia, which are down 90%. Axelrod noted that 194 U.S. companies have exited Russia and more than 600 multinationals have also exited the country.
Axelrod recommended companies looking to implement an export management program should invest in compliance on the front end and establish communication with their local trade compliance officers. These steps mitigate potential exposure or engagement with bad actors before the BIS office needs to enforce its rules. Companies can also take advantage of initiatives such as “no admit, no deny” by submitting voluntary self-disclosures before enforcement mechanisms engage due to violations.
Maria Suarez, Director Government Affairs, writes about industry-specific policies for the Energy Workforce & Technology Council. Click here to subscribe to the Energy Workforce newsletter, which highlights sector-specific issues, best practices, activities and more.