Publication | NYU Compliance & Enforcement Blog

A Fresh Look at the “Willful” Intent Standard for Criminal Liability in Export Controls and Sanctions Corporate Enforcement

Brent Carlson and Michael Huneke

February 13, 2024

The “90-Day Review Report” issued by the chairman of the US House of Representatives’ Foreign Affairs Committee in January 2024 claims that the “willfulness” standard for criminal prosecutions in US export controls is nearly impossible to meet, often resulting in administrative enforcement actions rather than criminal penalties.

Brent Carlson and Michael Huneke debunk a major myth and shed light on the realities of white-collar criminal enforcement, providing practical tips for companies to navigate compliance effectively amid increasing geopolitical risks and national security priorities.

Read the full article.

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Brent Carlson


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