Back to Basics
Back to Basics
Red Flags Rising by Michael Huneke & Brent Carlson
E33
Dec 2, 2025
28:24
Episode notes

As the geopolitical and national political winds continue to swirl, Mike & Brent go back to basics to level-set and provide some foundational first principles of export controls compliance. They discuss the roller-coaster of the Affiliates Rule suspension (01:44); why the real risks from a compliance and enforcement perspective lay just outside of the Rule (02:37); how General Prohibition 10, the full definition of “knowledge” to include “an awareness of a high probability,” and the various inchoate provisions (i.e., causing, aiding and abetting, solicitation and attempt, conspiracy, acting with knowledge, misrepresentation and concealment, intent to evade, and failure to comply with recordkeeping requirements) are the foundational anti-diversion provisions under the U.S. Export Administration Regulations (EAR) (03:02); great listener feedbac ... 

Keywords
Export Controls
Compliance Officers
Trade Compliance
High Probability Standard
Department of Commerce
Bureau of Industry & Security
Economic Security
National Security
Artificial Intelligence
A.I.
China
Semiconductors
Howard Lutnick
America First Trade Policy
End-Use and End-User Export Controls