The U.S. Has Work to Do at Home to Stop the PLA’s Modernization

By Steve Coonen In a sign that it still knows how to do at least one thing right, Congress has lately been busy preparing the U.S. military to fight and win against the People’s Liberation Army (PLA). In December, the annual National Defense Authorization Act (NDAA) passed the House of Representatives with increases in defense spending and military capabilities in the Indo-Pacific. These desperately needed steps will help America’s warfighters (and those of our partners and allies) deter Chinese military aggression. But these actions will ultimately be irrelevant if the Biden Administration and Congress do not similarly curtail China’s ability to use U.S. technology to modernize the People’s Liberation Army. Both branches of government would be wise to implement recent… Read More

Raimondo Talks Tough at Reagan Defense Forum But Challenges Remain  

Last weekend Secretary of Commerce Gina Raimondo spoke at the annual Reagan National Defense Forum, one of the signature events on the national security calendar. As the name might suggest, the gathering is traditionally popular with right-leaning national security figures, so credit a Democratic Secretary of Commerce for making an appearance. While she did have comments worth applauding, it’s clear the administration is still focused on advanced chips and needs to broaden its focus to counter threats at the legacy chip level for the sake of our national security and economic prosperity.   CTT has long argued that U.S. semiconductor equipment companies are putting cash over country (see our report by that name) by selling some of the world’s most sensitive… Read More

As BIS Prepares to Issue Updated Export Controls, A New Report from James Mulvenon Highlights SMIC’s Ties to Chinese Military

Three Years Later – Mulvenon Looks Back on His SMIC Findings In 2020, a report by cybersecurity expert James Mulvenon on Chinese chipmaker SMIC’s ties to the Chinese military undergirded the Commerce Department’s export controls targeting the company. Those controls (purportedly) cut off SMIC’s access to certain leading edge American technologies. But as Mulvenon and Joseph McReynolds write in a new report released in October 2023, “U.S. sanctions efforts to date have not been sufficient to deter SMIC; the firm has even opened a new Southern California office in recent months with public celebrations and fanfare.” The title of the authors’ work says it all: “SMIC Races Over BIS Speed Bump to Fulfill China’s Strategic Ambitions: Continued Troubling Activities Even… Read More

4 Export Control Fallacies and Their Rebuttals

By Steve Coonen Writing in the Wall Street Journal last week, professors Henry Farrell and Abraham Newman criticize American export control policies as having the potential to create more problems then they solve. Pointing the finger at America as a force for destabilization is divorced from the reality of the global export control landscape. China’s commitment to using American technologies to build up its military has necessitated export controls targeting the country’s chip sector. Here are four fallacies promoted in the article (in italics) and my rebuttals: Fallacy #1: The U.S. is to blame for export control-related global disruptions “A new tit-for-tat is emerging, and as China responds to the turn in American policy, there is a risk that the… Read More

Actions Speak Louder than Words—So Where’s the Action from the Commerce Department?

“Actions speak louder than words” was the refrain from Commerce Secretary Gina Raimondo on CBS’ Face the Nation last Sunday. Raimondo is referring to what she hopes to see from the Chinese government following her meetings in Beijing last week—not just promises of change, but concrete steps. The world shouldn’t hold its breath waiting for them. The Chinese Communist Party (CCP) can’t be trusted to uphold its promises—just ask the citizens of Hong Kong, who have seen their autonomy revoked in the last several years. Or maybe President Obama, to whom Xi Jinping made promises in 2015 that the CCP would stop militarizing the South China Sea. Or other nations in Asia, which are recently outraged after China released a… Read More

Actions Speak Louder Than Words – Willful Blindness Series Recap

With Labor Day around the corner, the unofficial end of summer is almost here. So, here’s our final plug for beach reading from CTT special advisor Steve Coonen. Coonen, who spent more than two decades in uniform as an Army artillery and foreign affairs officer and then nearly 14 years as an analyst at the Defense Technology and Security Administration (DTSA), wrote a nine-part summer series for CTT on America’s broken export control system.  The need to expose the administration’s willful blindless as it relates to export controls could not be more timely. Multiple outlets are reporting that one outcome of Commerce Secretary Gina Raimondo’s visit to China is an agreement between the U.S. and China to begin a series… Read More

How BIS Has Accommodated Corporations at The Expense of National Security

By Steve Coonen Recently I was asked, “On a scale of A to F, how would you grade BIS’s performance over the past 5 years?” My response: “If one removes ‘security’ (the S from BIS), then BIS fully merits an A+.” That’s not a compliment. For years BIS has accommodated corporations and industry groups at the expense of American national security. For starters, the Commerce Department’s core mission of advancing U.S. economic interests has prevented an appropriately rigorous approach to export controls. The Department of Commerce’s self-described mission is to “to create the conditions for economic growth and opportunity for all communities.” Consequently, BIS’s goal of denying the export of U.S. technology which can be used for military purposes is… Read More

Fixing the Failings of the Interagency Export Control Review System

By Steve Coonen As I established in my paper Willful Blindness released in May, the Commerce Department’s Bureau of Industry and Security (the unit within the U.S. government primarily responsible for stopping the Chinese military from obtaining American technologies) has become a rubber stamp for the export of controlled technologies to China. Case in point: In 2022, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) approved over 91% of applications for the export of controlled technologies to China, even greater than 2021’s 88% rate.  Yes, BIS needs to do a better job of denying tech exports to China. But BIS is not entirely at fault—it is just one cog in the broken federal machine tasked with defending U.S.… Read More

The U.S. Cannot Continue to Export Dual-Use Technologies to China

By Steve Coonen As anyone who has seen the new film Oppenheimer can attest to, the U.S. government has historically gone to great lengths to prevent military tools from falling into the hands of our adversaries. So why is the federal government continuing to rubber stamp the export of dual-use technologies to our greatest adversary? Dual-use technologies are those which can be used for both military and civil purposes. Some items common to both civilian and military hardware, such as nuts, bolts, screws, seals, etc., pose no national security concerns. But others do. For example, the seemingly innocuous carbon fiber filament used to make high-performance brake pads is also the same material used to manufacture nose cones for ballistic missiles.… Read More

Why BIS End-Use Checks in China Are Useless

By Steve Coonen Quoting an old Russian proverb, President Ronald Reagan once remarked, “Trust, but verify.” Reagan’s words may have been appropriate as the U.S. negotiated an arms control agreement with the USSR. But when it comes to inspecting how China is using American technologies, the U.S. government should adapt his words to go a step further: “Distrust and verify.” At their root, the Bureau of Industry and Security’s (BIS) end-use checks in China are practically useless. Under the terms of the U.S.-China end-use check agreement, it is impossible for U.S. export control officers (ECOs) to verify the ultimate destinations or end-uses of U.S. technology. With other countries, U.S. export control officers can conduct post-shipment verifications (PSV) with few restrictions… Read More