Red Flags Rising

Clarity from Chaos: U.S. Export Controls Enforcement Signals & What to Do About Them


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Mike & Brent connect the dots between the Administration's signals regarding U.S. export control enforcement, recent media reports, and how trade compliance teams can best prepare for what comes next. They discuss the overall climate of uncertainty (01:03), an April 8, 2025 report by Reuters about a potential large U.S. export controls fine in the works (01:35), how companies can best respond to a counterparty being put on the U.S. Bureau of Industry & Security's "Entity List" (05:47), how to respond to U.S. government outreach or administrative subpoenas (07:27), an April 10, 2025 report by Export Compliance Daily about a potential uptick in administrative subpoenas (11:39), their prior "Fresh Looks" post on responding to government inquiries (13:51), and conclude with another installment of Brent Carlson's "Managing-Up" (17:38).

Reuters article: Karen Freifeld, "Exclusive: TSMC could face $1 billion or more fine from US probe, sources say," Reuters (Apr. 8, 2025): https://www.reuters.com/technology/tsmc-could-face-1-billion-or-more-fine-us-probe-sources-say-2025-04-08/

Export Compliance Daily: Ian Cohen, "Gov't May Be Issuing More Export Control-Related Subpoenas, Industry Lawyer Says," ECD (Apr. 10, 2025) (subscription required): https://exportcompliancedaily.com/article/view?search_id=24312&id=2302224

More about Brent: https://www.linkedin.com/in/brent-carlson-41ba692/

More about Mike: https://www.linkedin.com/in/mhuneke/

Mike & Brent's "Fresh Looks" Series: https://www.hugheshubbard.com/fresh-looks

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Red Flags RisingBy Michael Huneke & Brent Carlson

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