The Obama administration has made admirable and high-profile efforts toward export control reform. There long has been a consensus among both security experts and exporters that our export control laws are too complex and overbroad and that substantial legislative changes are warranted. While Congress has been unable to pass needed legislative reforms, some reforms are possible without legislation, and the administration boldly has taken actions to streamline, standardize and simplify U.S. export control laws. In particular, in July, the administration proposed a significant rule to accomplish these ends.
As a precursor to this rule, the President issued a November 2010 Executive Order establishing an Export Enforcement Coordination Center (EECC). The EECC is to be housed within the Department of Homeland Security to coordinate the efforts of the multiple federal agencies responsible for enforcing our export control laws. The efforts to be coordinated include “public outreach activities.”
But the EECC has no apparent public presence. Searches for the EECC on the DHS website produce nothing. The website for DHS’s Immigration and Customs Enforcement (ICE) unit does contain passing references indicating that the EECC will be part of ICE – specifically ICE’s Counter-Proliferation Investigations Unit – once the EECC is established: “Once established, the center will enhance the United States’ ability to combat illicit proliferation. It will also serve as a hub for exchanging information and intelligence related to export enforcement.”
We’re almost 12 months past the date of the order establishing the EECC. By this time, in view of the EECC’s role in a major White House initiative, the EECC should have a dramatically higher public profile.