Office overview and responsibilities
The ICTS program implements four Executive Orders (EOs) and its related regulations under the International Emergency Economic Powers Act (IEEPA):”
- EO 13873, “Securing the Information and Communications Technology and Services Supply Chain,” (May 15, 2019) delegated to the Secretary of Commerce broad authority to prohibit or impose mitigation measures on any ICTS Transaction subject to United States jurisdiction that poses undue or unacceptable risks to the United States.
- 15 C.F.R. Part 7, “Securing the Information and Communications Technology and Services Supply Chain“ is the implementing regulation for EO 13873 and establishes the scope of an ICTS Transaction and creates a process for reviewing ICTS Transactions the Department or other agencies (through referrals) believe may pose an undue or unacceptable risk. The Department can, on its own accord or upon referral, investigate ICTS Transactions. Ultimately, the Secretary can prohibit or mitigate ICTS Transactions if those transactions pose one of the three risks outlined in EO 13873.
- EO 13984, “Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities” directs the Secretary of Commerce to propose rules to address malicious cyber actors’ use of Infrastructure as a Service (IaaS), by proposing “know your customer” (KYC) requirements.
- EO 14034, “Protecting Americans’ Sensitive Data from Foreign Adversaries” (June 11, 2021) builds upon EO 13873 to address threats posed by connected software applications linked to foreign adversaries.
- EO 14110, “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence” (October 30, 2023), builds on E.O. 13984, directing the Secretary of Commerce to impose record keeping requirements on IaaS providers when transacting with a foreign person to train certain large AI models.
Office leadership
Elizabeth Cannon
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Elizabeth Cannon
Elizabeth “Liz” Cannon previously served as Senior Corporate Counsel for Global Trade with Microsoft. In that capacity, she was responsible for monitoring export controls, sanctions, and other international trade and security policy issues. She also oversaw Microsoft’s Risk Intelligence Group, which conducts due diligence and trade-related investigations. Liz also brings more than a decade of public service and national security experience from the Department of Justice, including five years as Deputy Chief for Export Controls and Sanctions in the National Security Division. In this role, she supervised all criminal cases involving export control and sanctions violations around the country.
During her service at DOJ, she prosecuted national security cases, including matters involving espionage, economic espionage, mishandling of classified information, cyber offenses, and sanctions and export control violations. She has also spent time in private practice at an international law firm. She holds a BS in Commerce from the University of Virginia and a JD from New York University School of Law.
Evan Broderick
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Evan Broderick
Evan Broderick serves as the Deputy Director for the Information and Communications Technology and Services (ICTS) program at BIS. In this role, Mr. Broderick supports operations and policy development under Executive Orders 13873, 14034, 13984, and 14110. Mr. Broderick previously served as a Senior Cybersecurity Analyst within the National Telecommunications and Information Administration (NTIA) providing policy support to the Assistant Secretary for Communications and Information, the Secretary of Commerce and the National Security Council on various issues impacting the Internet and digital economy. Before NTIA, Mr. Broderick provided intelligence support as the Deputy Assistant Director for Strategic Intelligence to BIS, supporting the adjudication of export licenses for controlled technology.
Prior to his work within the Federal Government, Mr. Broderick served as a Senior Training and Development Specialist with Raytheon, training military intelligence specialists for the Department of Defense. Mr. Broderick also served over five years with the Army at Fort Lewis Washington, including two years in Iraq developing both tactical and strategic operational plans in his military career as a Brigade Master Analyst.
Mr. Broderick holds a B.S. in Professional Chemistry and a Minor in Mathematics from Bridgewater University and a M.A. in Criminal Justice with a certificate of Forensic Criminology from the University of Massachusetts.