Insights

Mastering the New Era of Export Controls: Understanding BIS’s "High Probability" Standard and Mitigating Enforcement Risks

March 5, 2025
Intelligence That Works

Brent Carlson and Michael Huneke (Hughes Hubbard & Reed) presented on the “high probability” standard under the US Export Administration Regulations. They discussed recent emphasis of this standard for increased enforcement activity by both the US Bureau of Industry and Security and Congress, including the December 18, 2024, report issued by the majority staff of the US Senate’s Permanent Subcommittee on Investigations.

This webinar provided practical strategies for mitigating increasing enforcement risks—driven by geopolitical dynamics—by applying this standard in corporate compliance programs and risk management for companies and their officers and directors.

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