Management Matters

One of the lessons I learned in government is that good management and good policy do not always coincide. Good policy can be compromised by poor management and implementation. Good management only makes bad policy worse. Incoming presidential administrations face the challenge of how to deal with the career bureaucracy that is charged with implementing policy. Some administrations choose to work closely with the career staff, trusting them to faithfully implement what the president and their direct leaders want. Others come in distrusting the career personnel and rely on a small group of political aides who are often unfamiliar with the laws they are tasked with administering. This leads to bad decisions and sloppy implementation.

Over the years, I have observed both strategies, but my experience in the executive branch running the Commerce Department’s Bureau of Industry and Security (BIS) convinced me that the first one works better. Career personnel primarily focus on successfully doing what their leadership asks. When they succeed, both they and their leaders look good.

One current example of the second approach is playing out at the agency where I learned that lesson—BIS. After a number of experienced, highly competent career officials were forced out, the current leadership has:

• decreed that all license applications have to be reviewed by the under secretary, resulting in a growing backlog that exceeds the mandated time limits—a recent CSIS survey found that more than half of survey respondents from the semiconductor sector reported average license review times exceeding 180 days, more than twice the 90-day limit;
• created a system in which the one reliable way to get action on a license is for a senior official of the applicant company to have a personal meeting with the under secretary;
• instructed the staff not to maintain contact with private industry and curtailed private-sector outreach and compliance training;
• failed to schedule the bureau’s long-standing update conference, a key opportunity for companies to get updates on BIS regulations and enforcement actions;
• allowed the bureau’s technical advisory committees to lie dormant;
• announced that the administration would not implement decisions of the Wassenaar Arrangement—the multilateral organization charged with coordinating a common approach to export controls among its 42 member countries—and would not be attending Wassenaar Arrangement meetings; and
• limited staff travel to other countries to exchange views on export control policies.
   

Of the many mistakes here, the two biggest ones are the effective severing of relations with U.S. companies and with foreign partners. With respect to the companies, the technology sector is fast-moving. New products are being developed constantly, and many of them have a shelf life of only a few years. The only people who really have a good grip on what is going on in high-tech research and manufacturing are those who are actually doing it. BIS has competent career experts in the sectors where it controls items for export, but they are not on site and have to get their information from those who are—the company employees. Limiting access to them guarantees that BIS will be behind the curve in understanding the latest technological developments.

In addition, the companies that make sensitive items are the frontline of export control compliance. BIS regulations begin with reliance on corporate due diligence. “Know your customer” is the bureau’s mantra. Effective enforcement requires a close working relationship with companies and extensive communication with them, in both directions. Companies need to know what the government is worried about, and the government needs to know what companies are seeing in the field—for example, what efforts are being made to acquire their products illegally, who is doing that, and where they are located. If those conversations do not occur, compliance and enforcement are handicapped.

The same applies to dealing with other countries. Successful export controls depend on multilateral cooperation. The United States is not the only producer of high-tech items, and in some cases, it is not the world leader. U.S. export controls without parallel efforts by our partners is equivalent to “damming half the river,” as former BIS Under Secretary Eric Hirschhorn said. One of the great accomplishments of the Biden administration was its success at bringing together some 38 nations to impose sanctions on Russia in the wake of its invasion of Ukraine. That took an enormous amount of diplomacy and hard work in a short period of time from career experts. Abandoning those relationships and pulling away from the multilateral structures that enable common approaches undermines everything the United States is trying to accomplish in its export control efforts.

It has been typical of the Trump administration to assume that because the United States is big, it can push everybody else around to get its way. The world of export controls does not work that way. Failure to nurture relationships with other high-tech producers like Japan, South Korea, Taiwan, Germany, and the Netherlands guarantees that the United States’ own controls will fail.

Today’s column is not about export control policy. I will discuss that another time. Today’s column is, instead, about management. If the bureau’s leadership does not run an efficient, transparent licensing system, abandons dialogue with the people it is regulating, and fails to cooperate with foreign partners, it will not achieve its policy goals—no matter what they are.

Author’s Note: I retired from CSIS on March 29, 2026. I plan to continue writing this column and participating in the Trade Guys podcast, so please continue to read and listen. However, my CSIS email address will no longer be working, so if readers or podcast listeners want to contact me directly, they should do so at [email protected].

William A. Reinsch is a senior adviser (non-resident) and Scholl Chair emeritus with the Economics Program and Scholl Chair at the Center for Strategic and International Studies in Washington, D.C.