The Bureau of Industry and Security as one of the Main Agents of US Sanctions Policy

Abstract

Relevance . Amidst the transformation of the global economy and escalation of geopolitical confrontation, sanctions mechanisms are increasingly being extended to strategically important and knowledge-intensive industries. This article examines the Bureau of Industry and Security (BIS) of the U. S. Department of Commerce as a key instrument for implementing sanctions policy in the area of export controls. The legal and regulatory framework (Export Administration Regulations — EAR), the licensing system, and specialized restricted-party lists (Entity List, MEU List, Denied Persons List, Unverified List) are analysed, shaping mechanisms of both primary and secondary sanctions. Based on an analysis of high-profile enforcement cases (Applied Materials, Luminultra, Microsoft, Exyte Management, Indium Corporation, airlines, Oleg Patsulya, and others), systemic patterns of violation prosecution are identified. A separate section is devoted to an empirical assessment of effects of BIS based on COMTRADE data (2015–2024): a structural gap in direct U.S.-Russian supplies of dual-use categories with an effectiveness of 99+ per cent is identified, as well as a statistically significant correlation with the growth of re-export flows through China and Kazakhstan. It was concluded , that BIS operates as an agent of extraterritorial economic coercion, stimulating the formation of indirect supply channels and imposing increased compliance requirements on third-countries counterparties.