BIS enforcement is examined through a conversation with Don Pearce, a former BIS agent, who recounts his career trajectory from 1997 to his retirement in 2020 and highlights the evolution of export control and enforcement. Pearce details the shift in focus from the Soviet Union to non-state terrorist actors and then to China and Russia, noting the increased cooperation among agencies post-9/11 and the role of E2C2 in de-conflicting investigations. He shares insights on the changing nature of investigations, the importance of outreach, and provides advice to companies on handling visits from government agents. He also emphasizes the critical role of due diligence and open-source intelligence in compliance, referencing specific enforcement actions and cases, including the Corzing case involving the Iranian Revolutionary Guard Corps.
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