The Trump Administration has filed its FY2027 budget request for the Bureau of Industry and Security (BIS), and it reads less like a government spending document and more like a declaration of war on export violations. The headline: BIS is requesting $450 million and 1,077 positions, a 91.5% funding increase and the largest single-year jump in the agency's history.
In BIS's own words, the goal is to protect "the crown jewels of the American economy" — U.S. advanced technology. However, nothing in the Bureau’s statement addresses building up the infrastructure of licensing, outreach, guidance, and support that helps the U.S. export economy run.
Whether your company exports semiconductors, aerospace components, AI software, medical devices, or robotics, that framing should get your attention. Here is what the budget tells us about where enforcement is heading, and what you should be doing about it now.
An Enforcement Surge
The single biggest line item in the request is $151.9 million to hire 290 new Special Agents and more than double the number of Export Control Officers stationed abroad (from 25 to over 65). BIS is also requesting 57 new analysts in its Office of Enforcement Analysis and 38 specialized engineers to serve as expert witnesses in criminal prosecutions. Commerce Secretary Lutnick told Congress that export enforcement agents “bring between 3 and 10 times their cost in fines annually,” so this budget may not be just a security investment, it could also be a revenue model.
The numbers on the ground already tell the story. In the first six and a half months of FY2026, BIS imposed over $258 million in civil penalties — a record pace that underscores the agency’s renewed focus on enforcement . With nearly 300 new agents coming online and analytical capacity expanding to match, we would not expect these numbers to be an anomaly but, rather, the baseline of future enforcement.
However, even if BIS gets its requested budget in FY2027, it may not help your export license applications to move any faster. The entire budget rationale is built around enforcement. There is no mention anywhere of addressing the existing license backlog or improving guidance for businesses, and nothing in BIS's public statements suggests that is a priority.
That line is consistent with reports that internal directives were issued to BIS licensing agents not to discuss cases informally with applicants or comment at all on any of the export license holds that were reportedly imposed internally at BIS in 2025. So, if your compliance program was built around the assumption that more resources at BIS would eventually mean smoother, quicker license approvals, it's time to revisit that assumption.
Section 232: Much Bigger Than Steel
If you think Section 232 investigations are someone else’s problem, you may want to check again. Since January 2025, BIS has launched a record 12 investigations covering sectors far beyond the traditional steel-and-aluminum perimeter, including the following:
- Copper
- Timber and Lumber
- Semiconductors and Manufacturing Equipment
- Pharmaceuticals and Pharmaceutical Ingredients
- Processed Critical Minerals and Derivatives
- Commercial Aircraft and Jet Engines
- Wind turbines
- Robotics
- Medical equipment
- Trucks; and
- Drones
The FY2027 request includes $19.8 million for 40 new analysts dedicated exclusively to administering and expanding the Section 232 program.
The practical implication: if your company imports goods in any of these categories, tariff exposure is a live and growing risk. The product inclusion and exclusion process is your lever, but it requires active engagement, not passive monitoring.
Five Things to Do Before the Clock Runs Out
The window to get ahead of this enforcement environment is narrowing, and one deadline is particularly concrete. The so-called "Affiliates Rule," which would extend Entity List and Military End User List restrictions to affiliated entities, is currently paused but takes effect on November 9, 2026. That is not a lot of runway.
Here is what we recommend you consider doing now:
- Audit your export compliance program against BIS's stated enforcement priorities: AI, quantum computing, semiconductors, advanced computing, robotics, medical devices, and biotechnology.
- Map your global supply chain for transshipment exposure — routes through third countries that have historically been low-risk are increasingly in the crosshairs of newly deployed Export Control Officers.
- Assess your Affiliates Rule exposure before November 9. If any of your distributors or customers are affiliated with Entity List parties, your due diligence obligations are about to expand significantly.
- Track Section 232 developments in your sector and engage proactively in the product inclusion/exclusion process.
- Address unresolved compliance issues now. BIS Assistant Secretary David Peters has publicly supported extending the export control statute of limitations from 5 to 10 years. If that passes, yesterday's problem becomes tomorrow's indictment.
The BIS budget request is not enacted law. Congress will set final FY2027 appropriations. But the direction of travel is unmistakable, and enforcement agencies rarely need to wait for their full budget to start using the tools they already have. The agents hired in FY2026 are already working cases.
The crown jewels are being guarded. The question is whether your compliance program is ready for the guards.