Red Flags Rising

FRESH LOOKS - Loopholes and Liability Pitfalls


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Mike & Brent revisit Brent's original August 25, 2023, "Fresh Looks" post, "When Loopholes Create Liability Pitfalls: A Fresh Look at Export Controls." They discuss what inspired Brent to write the article (00:40), the Inspur Group controversy (05:38), what legacy perspectives were missing about the compliance and enforcement risks (08:25), parallels to U.S. Foreign Corrupt Practices Act enforcement (12:16), why Mike initially hated Brent's article (13:19), how the risks that Brent highlighted in August 2023 are still relevant today (17:29), the key takeaways for trade compliance professionals (18:29), and the return by popular demand of Brent Carlson's "Managing Up" segment on what trade compliance should explain to stakeholders, management and boards about the risks identified in Brent's article (20:41).

Check out Episode 2 for more on Secretary Lutnick's March 18, 2025, remarks at the BIS Update conference (see the show notes for additional reporting)

Brent's NYU PCCE Post: https://wp.nyu.edu/compliance_enforcement/2023/08/25/29814/

The entire "Fresh Looks" series: https://www.hugheshubbard.com/fresh-looks

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

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

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Red Flags RisingBy Michael Huneke & Brent Carlson

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