Why It Matters

The Export-Import Bank (EXIM) has effectively stopped financing dual-use exports, goods and services with both military and civilian applications, leaving a three-decade-old congressional mandate without active transactions to oversee.

A Government Accountability Office (GAO) report released August 21, found that as of that date, EXIM was not monitoring the end use of any dual-use export because all prior transactions had been repaid in full. The bank financed no new dual-use exports in fiscal year 2025.

The Big Picture

In 1994, Congress passed legislation authorizing EXIM to facilitate financing of U.S. exports of defense articles and services with both civilian and military applications.

The law imposed a critical constraint: such dual-use items must be nonlethal and primarily intended for civilian rather than military purposes.

The same legislation included a provision requiring the GAO, in consultation with EXIM, to report annually on the end uses of dual-use exports financed by the bank during the second preceding fiscal year.

The Bottom Line

The absence of active dual-use export financing raises questions about whether EXIM is fulfilling its statutory role in an era when such exports have ceased.

Congress may need to revisit whether the 1994 authorization and the annual GAO reporting requirement remain necessary, or whether they should be updated to reflect the current state of the export financing market. Until then, the mandate persists even as the underlying activity has vanished.

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