On April 9, the Research Institute for Democracy, Society, and Emerging Technology (DSET) welcomed Mi-Yong Kim, former senior official at the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), for a keynote speech on the evolution of U.S. export control policy over the past 30 years as well as strategic insights for Taiwan as it prepares for potential negotiations with the Trump administration.
Kim brings nearly three decades of expertise in export control policy from both the U.S. government and the private sector. She previously served as an export control advisor at the American Institute in Taiwan (AIT), where she helped build Taiwan’s foundational regulatory framework. She currently serves as a Senior Technical Specialist at National Chengchi University, where she teaches export control-related courses.
At the event, DSET also officially appointed Kim as a Visiting Scholar. In this role, she will support Taiwan’s export control reform efforts through a series of public lectures and private roundtables hosted by DSET.
The event was moderated by DSET Executive Director Dr. Jeremy Chih-Cheng Chang and attended by DSET President Wen-Ling Tu, Vice President Hsien-Ming Lien, and Advisors Wen-Ling Hong and Sen-Ran Chen. Around 50 participants—including journalists from local and international media, legal scholars, and semiconductor industry professionals—were present.
Dr. Chang noted that since its founding, DSET’s Economic Security Research Program has focused on strengthening Taiwan’s export control regime. Ms. Kim has long been a trusted advisor in these efforts. On April 6, President Lai Ching-te emphasized Taiwan’s intention to “resolve long-standing U.S. concerns over high-tech export controls” as part of any future trade negotiations with the Trump administration. DSET will contribute policy recommendations in support of this goal, and Kim’s appointment and lecture mark the beginning of a new phase in this dialogue.
In her remarks, Kim reflected on her time at AIT, where she supported Taiwan’s efforts to establish an export control system. While progress was made, she noted that gaps remained—particularly in regulating sensitive technologies. She expressed optimism that President Lai had identified export control reform as a priority in cross-strait and U.S. trade negotiations.
When asked about specific reforms, Kim pointed to the need for greater technical precision in Taiwan’s existing regulations, including clearer definitions for controlled technologies such as chip performance thresholds. She also noted that, at present, Taiwan’s export controls remain primarily focused on China; however, given the current global landscape, it is also necessary to comprehensively strengthen controls on technology transfers to countries beyond China.
On Taiwan’s negotiation strategy with the United States, Kim advised against revealing positions too early. She encouraged Taiwan to follow the lead of countries like Canada and the European Union (EU)—building coalitions and responding collectively to U.S. demands. This approach, she said, would place Taiwan in a stronger bargaining position.
Dr. Chang also raised a Reuters report published earlier that day suggesting that TSMC could face a fine of up to USD 1 billion (approximately NT$33.2 billion) for alleged chip exports to Huawei. Kim said she could not verify the accuracy or amount of the reported fine but acknowledged that similar rumors had circulated within the export control community. The leak, she noted, could be a prelude to an official enforcement action.
Drawing on her BIS experience, Kim explained that maximum fines are rarely imposed in administrative export control cases. Companies that voluntarily disclose violations or can demonstrate inadvertent error often receive reduced penalties, suspended fines, or alternative remedies. She emphasized that this situation differs from the ZTE case, which involved both criminal and administrative violations and resulted in significantly harsher sanctions.
When asked whether political motives might drive a future Trump administration to insist on the maximum fine, Kim said she had no insight into current internal discussions. However, she acknowledged the possibility and expressed hope that the Commerce Department’s legal team would follow due process.
Kim also addressed broader institutional challenges facing BIS. She noted that the departure of experienced personnel has weakened the agency’s capacity to review licenses and enforce regulations. A lack of communication with industry has hindered the timely identification and correction of policy flaws. The U.S. withdrawal from multilateral negotiations has diminished the global impact of American export controls. And without sufficient technical expertise in sectors like semiconductors, regulatory enforcement remains difficult.
During the Q&A session, CommonWealth Magazine Editor-at-Large Liang-Rong Chen referenced a recent CSIS report identifying loopholes in U.S. export controls on Nvidia and questioned whether the Commerce Department lacks insight into industry dynamics. Kim responded that the Department has long struggled to recruit engineers with the necessary technical depth and industry knowledge. As a result, companies often find ways to circumvent controls before regulators can catch up. With public service conditions worsening, many experienced BIS officials have chosen retirement, and recruiting qualified replacements remains a challenge. These trends, she warned, may complicate any future efforts by the Trump administration to expand export controls or enforce penalties effectively.
