Controls in Pop Culture

Men in Black—Models of Export Compliance!

Men in Black: International is almost here, and it got us thinking about how our favorite secret organization governing extraterrestrial activity on Earth is actually an exemplary model for export compliance.

No, seriously—you might think we’re joking, but we’re not. Over the course of the last three movies, the Men in Black (MIB) have shown themselves to be at the top of the compliance game from which we, in the real world, could all stand to learn. Admittedly, we aren’t dealing with extraterrestrials posing an existential threat to life as we know it as, the Men in Black are, but the same principles still apply.

Here’s a quick rundown of how organizations can learn a thing or two about export compliance—courtesy of the MIB.

The Men in Black—clearly committed to Restricted Party Screening

MIB are first and foremost overseers of extraterrestrial visitors to Earth. How do they accomplish this? By making sure that unsavory aliens, or those that might be deemed to be a threat to humankind, don’t get entry beyond the MIB headquarters. One could safely assume that they functionally “screen” every extraterrestrial who lands on Earth before they are given the okay to roam among us. By that extension, screening is how they have been able to help keep Earth safe for so long. Though what watch lists they screen against shall remain a mystery!

This, of course, serves to show the importance of screening everyone your organization does business with. While it is unlikely that any of them are grotesque extraterrestrial creatures in disguise looking to annihilate the Earth, they could still be engaged in nefarious Earthly activities that governments around the world frown upon—such as terrorism and money laundering. By association, this can get any organization in trouble as well. The more you screen for denied and restricted parties to make sure everyone you transact with is in the clear, the better the odds that you will be in the clear too!

The Men in Black—committed to controlled technology compliance

The other export compliance-related theme in Men in Black, of course, is how they keep tabs on the technology that passes to and from alien hands. The first film, as an example, saw MIB attempting to keep a source of subatomic energy out of the hands of an alien bug who quite likely would have used it to wreak havoc on what and who knows where. Which means that in addition to screening, MIB is seeking to prevent controlled technology from landing in just anyone’s hands.

With this in mind, one can logically assume that the Men in Black are diligent about ensuring no controlled technology passes through to Earth beyond their HQ. In fact, they are so diligent, they don’t even want the ordinary people of Earth to know that aliens—and their technology—even exist. Cue the neuralyzer—the device they use to wipe the memories of anyone who may have had any contact with any alien technology (or the MIB in general). And for the record, the MIB is so secretive that as of the date of posting, “neuralyzer” has yet to be added to the United States Munitions List (USML)!

While we don’t recommend attempting to wipe the memory of unauthorized people who come into possession of your controlled technology, we do recommend prevention—that is, making sure you are doing your due diligence with classification, licenses, and all relevant documentation so that your controlled technology doesn’t end up in the hands of someone on a denied or restricted party list, or being shipped to a sanctioned or embargoes country. That way, you won’t find yourself ever wishing you had a should a government agency come knocking on your door.

Take an export compliance cue from the MIB

The stakes are high with the MIB, which is obviously why they can’t afford to be lax with their compliance measures. And while your organization may not be the only thing that stands between society and an extraterrestrial invasion, it is no less off the hook as far as export compliance obligations.

Not being careful about who you do business with, or who and where your products and technology end up, can lead to unwittingly aiding terrorists, criminals and other debarred parties. That road can lead to potential fines, criminal and civil liabilities, not to mention the bad press and publicity that can lead to a loss of business opportunities. So be like the Men in Black, and do your due diligence. We simply suggest not wiping people’s memories.


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