Comments on Foreign Policy-Based Export Control (specifically the Entity List)

Mr. Jeffrey Lynch
Regulatory Policy Division
Bureau of Industry and Security
U.S. Department of Commerce
14th Street and Pennsylvania Avenue, NW
Room 2705 Washington, DC 20230

RE: Comments on Foreign Policy-Based Export Controls

Dear Mr. Lynch,

The Wisconsin Project on Nuclear Arms Control is pleased to submit the following in response to the September 8, 2008 request by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) for comments on foreign policy-based export controls (73 Fed. Reg. 52006). The Project is a non-profit organization that conducts outreach and public education to inhibit the proliferation of mass destruction weapons and their means of delivery. For more than twenty years, the Project has pursued its mission by advocating strong and effective export and transit controls worldwide.

The Project commends the commitment by BIS to improve the efficiency and transparency of dual-use export controls while safeguarding U.S. national security and economic competitiveness. The Project also welcomes the willingness by BIS to engage with all stakeholders to review comprehensively its administration of these controls. But in conducting these reviews and launching initiatives to increase efficiency, BIS should exercise great care when considering reduction or elimination of controls on entire categories of items, end-users or transactions. Just as changes in controls may have unintended consequences for the competitiveness of American businesses, so, too, such changes may prove detrimental to national and international security. This inherent risk is especially high with respect to proliferation controls.

To read the complete letter, click here:  Comments on Foreign Policy-Based Export Control (specifically the Entity List)