A Concept of Training in Export Control Culture

Among the most important tools to improve the effectiveness of export controls are internal compliance mechanisms established within exporting companies and facilities to ensure that all export control requirements are followed and properly implemented. Such mechanisms represent the first line of control over sensitive exports, before the license application process has begun. Most countries, including Russia, have undertaken several important steps towards establishing internal compliance programs within the organizations that export sensitive products and equipment. However, at many facilities, export control officers are assigned to export promotion departments, which puts them in the precarious position of having to balance the commercial interest of the organization with the requirements of export controls. Due to continuous economic hardships in some countries, the decisions reached by these officers are often predetermined by financial imperatives. Under such circumstances, the personal integrity of export control officers, their awareness of the importance of nonproliferation for national security, and their knowledge of export control laws and regulations constitute the main bulwarks against illicit exports. Many, if not all, of these characteristics can be included in the notion of “export control culture.” Accordingly, export control culture is defined as based not only of the technical skills internal compliance personnel need to follow the relevant norms, standards, and requirements, but also on the motivation of these personnel to promote these standards. Russia’s top export control officials have already acknowledged the need to cultivate such culture, and we use the case of Russia to illustrate why export control culture is needed and how to promote it.