Will the DoC Enforce the CVR Strictly from Day One?
Experts weigh in on how enforcement of the CVR might unfold—and why early flexibility could be on the table.
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Will the DoC Enforce the CVR Strictly from Day One?
Transcript
I am curious, I imagine some of your members are as well, as to how rigid, how strict, commerce is likely to be at both implementing and enforcing the rule whether right out of the gate or farther down the road.
Yeah. I I wish I knew. I don't know I don't know the answer but I I have, two thoughts and they're actually opposite thoughts. So but I'm gonna share them both because it may be insightful.
So one is, you know, this is the first one. This is the first ICS rule that BIS has done. So in some respects, I suspect that they will want to make an example of this. They want to send a message to all of the future sectors that are going to be covered by ICTS rules that this is serious.
They need to take this seriously. They need to be engaged in the rulemaking process. They need to be prepared to comply. So that leans towards like, yeah, I think they might, you know, be rather strict on enforcement.
The flip side of it is it's the first one.
And none of us, right, BIS, the auto industry really knows how this is gonna play out in practice and and we're sort of, in a way, flying the plane while we're building it. Right? So and I think BIS gets that and that there's some level of understanding that this may be bumpy out of the gate. And what leads me a little bit to think it's maybe the latter rather than the former is that BIS has been very clear, at least to us at least, that they suspect that there is going to be a need for a fair number of specific authorizations at the front end of implementation here, that folks are gonna find out that they need more time, that they're gonna discover an issue that they're not gonna be able to resolve in time.
And there seems we don't take this to the bank, but there seems to be an openness to be fairly flexible and forgiving with those specific authorizations in the early days. Not a long term solution. It's gonna buy you maybe a little bit more time, but maybe an openness to doing that to help folks navigate, this out of the gate.