Running To and Through the Export Controls Investigation Finish Line - Avoiding Resolution Pitfalls and Monitoring What Matters

Red Flags Rising por Michael Huneke & Brent Carlson

Notas del episodio

Mike and Brent take a break from Affiliates Rule (delayed) suspension news to focus on practical advice for companies that might be in the middle of U.S. government investigations into alleged export controls violations. They discuss the importance of engaging with the government with an awareness and an appreciation for the latest enforcement trends and signals, particularly regarding the government’s emphasis on the full definition of “knowledge” to include “an awareness of a high probability” (00:49); the importance of not being surprised by these trends in the middle of an investigation (02:52); the dangers to the cost, delay, and outcome of any investigation for failing to perceive the signals through the noise (04:08); the particular relevance of these strategies in defending against allegations of entity-shifting (09:48); the need to consi ... 

 ...  Leer más
Palabras clave
Export ControlsCompliance OfficersTrade ComplianceHigh Probability StandardDepartment of CommerceBureau of Industry & SecurityEconomic SecurityNational SecurityArtificial IntelligenceA.I.ChinaSemiconductorsHoward LutnickAmerica First Trade PolicyEnd-Use and End-User Export Controls