Audit of the Bureau of Industry and Security’s Enforcement of Russia and Belarus Export Controls

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Title Full

Date Issued

Monday, May 4, 2026

Submitting OIG

Department of Commerce OIG

Agencies Reviewed/Investigated

Department of Commerce

Report Number

OIG-26-019-A

Report Description

The Bureau of Industry and Security (BIS) administers and enforces U.S. export regulations to control the export of goods and technologies for national security and foreign policy purposes. Our objective for this audit was to assess the effectiveness of BIS actions to detect violations of export controls for Russia and Belarus in fiscal years 2022 and 2023.

BIS prevents the diversion or misuse of export-controlled items abroad by conducting pre-license checks and post-shipment verifications—collectively known as end-use checks—on foreign end users for individual export transactions, to help ensure that U.S. exports are being used as intended and to assess the legitimacy of end users.

Overall, we found that BIS needs to strengthen its end-use check process to prevent restricted shipments to Russia and Belarus. Specifically, we found weaknesses in BIS methods to identify and select high-risk shipments for end-use checks; document results and assign final ratings of compliance with export control regulations; and complete enforcement actions to hold potential violators of export controls accountable. These weaknesses undermine the transparency and accountability of BIS’s regulatory oversight and underscore the need for improvements to strengthen and modernize the end-use check process.

We made six recommendations to strengthen and modernize the end-use check process.

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

External Link

https://www.oig.doc.gov/reports/?entry=68423

Open Recommendations

This report has 5 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
We recommend that the Assistant Secretary for Export Enforcement develop policy and guidance that: a. Defines the methodology for target selection, including reviewing historical information when selecting a shipment for an end-use check and developing and conducting risk assessments to help inform the selection. b. Requires documentation to support the analysis used to target high-risk shipments for end-use checks. c. Defines the required process steps that export compliance specialists should perform when executing the end-use check process. d. Requires that supporting documentation for end-use checks be maintained centrally to support the selection and final rating. e. Requires that end-use check documentation include a justification when recommended actions are not implemented. f. Requires completion of risk assessments to determine effectiveness of the targeting strategy. g. Provides consistent methods for nominating or adding entities to the Unverified and Entity Lists for violations of export controls. h. Describes the roles and responsibilities for supervisors that, at a minimum, describe how to verify that end-use checks align with BIS targeting priorities and guidelines, require that supporting documentation be included in a central repository, require documentation of changes to final ratings, and confirm that all required actions, including adding violators to concerned party lists, are completed before closing the end-use checks in IMS-R.
2	No	$0	$0
We recommend that the Assistant Secretary for Export Enforcement develop and conduct training for export compliance specialists and supervisors on the documented end-use check process and standard operating procedures.
4	No	$0	$0
We recommend that the Assistant Secretary for Export Enforcement, based on recommendation 3, implement a systematic process for targeting end-use checks for shipment transactions, including the establishment of red flags and trend reports.
5	No	$0	$0
We recommend that the Assistant Secretary for Export Enforcement establish and implement oversight controls that ensure supervisors are verifying that follow-up actions to hold export violators accountable are completed when closing end-use checks in IMS-R.
6	No	$0	$0
We recommend that the Assistant Secretary for Export Enforcement conduct an assessment to determine the appropriate number of high-risk shipments to be selected for end-use checks, ensuring the selection is sufficient to effectively mitigate potential compliance risk.