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As Russian losses mount in Ukraine, Moscow is under increasing pressure to obtain the technology it needs to sustain its military. Russia relies on imports of advanced technologies, such as microelectronics used in missiles, from the West. Washington’s export controls are designed to combat exactly these kinds of supply-chain linkages. However, the U.S. enforcement system is struggling to keep pace. One problem is that Washington’s export controls are overseen by a federal agency that is both understaffed and underequipped: the Bureau of Industry and Security (BIS).

The work of BIS—an agency within the Department of Commerce that seeks to prevent foreign adversaries from gaining access to U.S. military technology—has become even more important amid Russia’s war and rising U.S.-China tensions. But the bureau does not have adequate resources to respond to these challenges, as we at the Center for Strategic and International Studies (CSIS) found in a recent report. BIS has only 448 employees—a small number compared, for example, to the International Trade Administration, which employs roughly 2,144 people. More importantly, its export control enforcement program is in urgent need of a technology upgrade—and the funding to make that possible.

Since the collapse of the Soviet Union, the U.S. export control system has changed dramatically. During the Cold War, controlled items were largely physical in nature, such as machine tools, and could be inspected at the border. In addition, the controls often applied to broad geographic areas, making for a somewhat simpler enforcement regime. For example, the United States presumed that dual-use goods—or items that could be used for both civilian and military purposes—exported to the Soviet Union would ultimately be used by the military and therefore banned their export there altogether.

Over the past 30 years, the system has become much more complex. Washington has largely shifted away from embargo-style controls to ones that target specific entities using sensitive items—a process that has significantly expanded the scope of controlled exports. Export control enforcement has also been complicated by the fact that intangible goods such as software have increasingly made up a greater share of U.S. exports.

Take Washington’s approach to Moscow. After Russia’s invasion of Ukraine in February, BIS imposed tighter restrictions on exports to Russia, including instituting new license requirements for controlled items, such as semiconductors, microelectronics, telecommunications, lasers, sensors, navigation equipment, marine equipment, and aircraft components. BIS also expanded the list of Russian entities prohibited from receiving U.S. goods altogether.

Despite this profound shift in U.S. export control policy, enforcement remains largely analog. Rather than using advanced technological capabilities to enforce export controls, BIS engages in outreach at home and abroad to keep the private sector, international governments, and other stakeholders current on evolving U.S. rules and regulations. The private sector seeks licenses from BIS for permission to export dual-use goods abroad. If BIS determines that an export would not compromise U.S. national security or foreign policy, it approves a license.

BIS also sometimes performs pre-license checks to ascertain the bona fides of a consumer as well as onsite reviews post-export, where an officer stationed abroad visits foreign firms and conducts inspections to ensure that the use of controlled technology is consistent with the terms of the license—meaning it is not being used for military purposes.

The work of BIS officers abroad is arguably the bureau’s most valuable asset. These officers maintain deep subject-matter expertise and often foreign language skills. However, BIS currently employs fewer than a dozen export control officers, meaning a single officer oversees vast regions—for example, all of Latin America, or Eastern Europe and Russia combined.

BIS also relies on tips from the private sector to determine which entities to investigate. For example, if one company hears of a competitor’s wrongdoing, it can alert BIS, which can then initiate an investigation. Investigations are also often carried out via search engines like Google, making them labor- and time-intensive and requiring that staff spend most of their time conducting research rather than analyzing information that could lead to enforcement action. Our research at CSIS suggests that BIS agents currently spend 80 percent of their time gathering data and only 20 percent evaluating the data for red flags.

This approach to export control enforcement relies on the assumption that a small team of analysts, in concert with officers, can comb enough data to prevent major gaps—and on very tight timelines. But this is unrealistic in today’s globalized economy. The private sector and other government agencies, such as the CIA, can arguably catch more nefarious activity with technology that combines open-source—or publicly available—data into one database.

A lack of substantial funding from Congress to equip BIS with these existing tech capabilities has prevented the agency from deploying similar systems. BIS’s budget has not increased commensurate with the growing number of export-controlled items, evolving geopolitical threats, and increasingly intangible nature of certain exports.

It is not just stricter controls on Russia that have made enforcement more complex. The ongoing trade war with China has been a significant factor as well. On Oct. 7, the Biden administration issued new export controls that, among other things, blocked the sale of advanced semiconductor chips to China without a license. The rules apply to all entities within China—not just the Chinese military, reflecting Washington’s understanding that China’s “civil-military fusion” doctrine makes it hard to distinguish between military and non-military importers. These controls signal a seismic shift in the U.S. approach to dual-use items, at least when it comes to China, back to the broad geographic controls of the Cold War era.

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As the scope of export controls grows, so too does BIS’s workload. BIS processed 41,446 export license applications in fiscal year 2021, representing a 9.4 percent increase from the preceding year. This upward trend of work for BIS is unlikely to subside. For example, BIS estimates that following the new chip regulations, analysts will need to review an additional 1,600 licenses annually.

Despite these strains, the Biden administration has repeatedly struck an optimistic tone about BIS’s ability to enforce export controls. In December, BIS Undersecretary Alan Estevez noted that Western export controls are “squeezing Russia’s military reconstitution capability.”

Yet there is reason to question the efficacy of current U.S. export control enforcement.

An investigation by Reuters and the Royal United Services Institute has shown that Russian weapons systems being used in its war in Ukraine contain U.S.-produced microelectronics. The Russian defense sector also remains optimistic about its ability to evade export controls. Alan Lushnikov, the president of Russian weapons manufacturer Kalashnikov, said in August that there were “no problems” obtaining chips because it was “impossible to isolate Russia from the entire global electronic component base.” As Russia becomes increasingly desperate, its efforts to circumvent sanctions and export controls are likely to increase.

These are tactics that Russia has fine-tuned over time. The acquisition of Western technology has featured prominently in Moscow’s military strategy since the Cold War. This was historically achieved via Soviet “dummy businesses,” or shell companies, that claimed false identities and acquired U.S. technology meant for Western Europe and Japan. A version of these tactics is occurring today in Russia’s acquisition of microelectronics via third countries, such as Turkey and Armenia.

BIS is in desperate need of funding to address these challenges. Already, the bureau has requested a $191 million budget for the 2023 financial year—44 percent more than the previous year—which it seems poised to receive in a new omnibus spending bill. A significant part of this increase, however, would go to a currently unfunded BIS program that assesses national security risks of supply chains for imported information and communications technology. While a substantial uptick in funding for BIS is laudable, Congress should appropriate additional funds—if not this year, then next—for the development and deployment of new technology to close important gaps in export control enforcement.

As our report at CSIS found, if Congress allocates an additional $45 million to the bureau annually every year for five years as a starter kit—a trivial amount compared to overall U.S. support for Ukraine, which reached roughly $50 billion in 2022—BIS will be able to adopt essential software upgrades and make significant staff increases.

Existing software that combs billions of records in real-time could facilitate the rapid identification of supply chain connections to, for example, Chinese and Russian military end-users. It would do this by reconciling disparate data sources, such as addresses, financial relationships, overlaps among employees, and geolocation of cargo ships, including ones that have turned off location-identifying capabilities. At BIS, open-source data would also be cross-checked with classified intelligence. Altogether, this could reveal illicit ownership of a company in a country of concern—even one using falsified records and shell company documents—and help determine which entities to investigate.

An enforcement system with greater automation would have critical national security implications. For one, it would substantially increase BIS’s productivity, allowing for far greater human-led evaluation of large datasets. It would also lead to swifter identification of circumvention, accelerate the licensing process by helping BIS analysts quickly determine the credibility of exporters and consumers, and more directly degrade adversaries’ military capabilities by making it harder for them to evade U.S. export controls.

In the United States, matters historically deemed critical to national security now increasingly bleed over into economic policy, reshaping strategic competition and affecting how Washington governs international commerce. This new approach to trade, technology, and economic statecraft is nothing short of a sea change.

As Congress considers funding the next generation of U.S. national security programs—and as the complexity and scope of export controls continues to grow—it should prioritize BIS to make a small but lasting impact on national security. Providing additional funding for BIS will ensure a more rapid degradation of the Russian war machine, build the architecture for widening controls on technology transfers to China, and bolster a small but agile agency at the very heart of geostrategic competition.