"the commerce department had been policing hundreds of billions of dollars in controlled exports using outdated tools for too long" [hundreds of billions of dollars]
Banks and Warren explicitly state that license decisions should not rest on 'assurances from executives who have a financial stake in the outcome.' This represents a regulatory pivot: the government is moving away from trust-based licensing toward verification-based licensing. The Chip Security Act's location verification requirement and the FCC's shift to domestic-only certification of network hardware reflect the same underlying dynamic—a loss of confidence in corporate self-policing as a control mechanism.