Publication | NYU Compliance & Enforcement Blog

A Fresh Look at the Evolution of Export Controls Penalties

Brent Carlson and Michael Huneke

November 14, 2023

New export control rules from the US Department of Commerce have put multinational companies on alert amid growing economic and geopolitical competition. Brent Carlson and Michael Huneke explore the evolution of export control penalties and compare them to those of the Foreign Corrupt Practices Act (FCPA). While penalties for export controls violations historically have been lower, recent cases suggest a changing landscape.

The authors address how companies can reassess compliance strategies, update risk assessments, and prepare for increased scrutiny and investigations to safeguard corporate integrity and shareholder value.

Read the article.

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Brent Carlson


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