Willful Blindness V2

An Insider’s Account: Steve’s Columns

Willful Blindness Highlights

  • Stephen Coonen’s Career and Perspective
  • China’s Military-Civil Fusion Renders U.S. Export Controls Irrelevant
  • The U.S. Government Rubber Stamps Technology Transfers to China
    • 3 Ways BIS Sidelines Other Federal Agencies
    • Huawei and SMIC Expose Ineffective US Export Control Policies
  • Complacency: Why Export Control Policy Remains Broken
    • 6 Flawed Rationales for Approving China Licenses
    • U.S. End-Checks in China and Entity Listings Do Nothing to Stop China from Diverting U.S. Technology to the PLA
  • 8 Recommendations for Strengthening Export Controls to Defend Sensitive Technologies
Receiving the Superior Civilian Service Award
Receiving the Superior Civilian Service Award



Part 1 – Stephen Coonen, Pentagon Whistleblower
Part 2 – A Willful Blindness Characterizes the Actors
Part 3 – Recommendations to Fix Export Controls

In The News

BIS ‘Completely Failing’ to Stop Sensitive Tech Exports to China, Former DOD Official Says

by Ian Cohen | 11 May 2023 | exportcompliancedaily.com

A former Pentagon official expected to testify before Congress May 11 said U.S. officials for years have “refused” to fix failures in its export control system that allow China to acquire sensitive technologies. Stephen Coonen, who spent nearly 14 years in the Defense Technology Security Administration, including as its senior foreign affairs adviser for China, said he resigned from the agency in 2021 to protest the Bureau of Industry and Security’s “willful blindness” surrounding its export policies.

He accused “senior decision-makers” at the Commerce Department of being “preponderantly influenced by industry voices advocating against tighter export controls,” adding BIS is plagued by “bureaucratic obstinacy.” The agency “routinely” ignores recommendations from other agencies when assessing commodity classifications and fails to coordinate with other agencies on license applications.

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Export Controls Can’t Keep Up With Adversaries, Analysts Say

by Micah Danney | 11 May 2023 | law360.com

U.S. agencies and allies need more flexibility and authority to prevent adversaries from obtaining sensitive technologies, said analysts who described a complicated and evolving national security landscape to the House Foreign Affairs Committee on Thursday.

Coonen urged making the presumption of denial the standard for all national security control technologies and other technologies deemed critical. He also recommended giving the DOD and the State and Energy departments more authority to quickly add restrictions for emerging, unlicensed technologies.

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US-China Tech Export Approval Rate Proof of Policy Failure, Says Ex-Pentagon Analyst

By Mark Tyson | August 17, 2022 | tomshardware.com

Strident-sounding U.S. tech sanctions on China don’t bite very hard. Official data from the Commerce Department shows the U.S. approves almost all tech export requests to China, according to a new Wall Street Journal report.

The data reveals that, in 2020, of the <0.5% of exports to China that required a license to be exported, 95% were approved. In 2021, the approval rate dropped to 88% — meaning nearly nine out of 10 tech export licenses were still greenlit.

Remember, the purpose of these sanctions is to deny China access to technology which could be purposed (or re-purposed) for use in military equipment. This implementation is falling by the wayside, according to critics who have seen the figures. Important U.S. semiconductors, AI technologies, and even aerospace components are still getting approved for export, according to the WSJ.

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