Publication | NYU Compliance & Enforcement Blog

When Loopholes Create Liability Pitfalls: A Fresh Look at Export Controls

Brent Carlson

August 25, 2023

The pace of change with export controls has accelerated dramatically in recent years, propelled by powerful geopolitical and national security drivers. The US Department of Justice (DOJ) has made it clear that sanctions and export controls constitute a new top enforcement priority.

The rapid pace of change has left many companies struggling to catch up with new risk management challenges. Certain assumptions and practices around export controls have become not only obsolete but increasingly landmines leading to disastrous potential criminal liability.

By adopting a white collar enforcement perspective to export controls compliance, companies and individuals may avoid creating unnecessary potential criminal liability pitfalls.

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Brent Carlson


San Francisco Bay Area