BIS Primes the Corporate Enforcement Engine
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And a Proposed Framework for How US Companies Can Best Prepare
The US Bureau of Industry & Security (BIS) is ramping up its enforcement actions against companies evading export controls. This approach mirrors the Department of Justice’s (DOJ) successful Foreign Corrupt Practices Act (FCPA) enforcement strategy.
A new mindset is required to identify and assess corporate criminal enforcement risks for both internal risk assessments and external interactions. Once data is shared with an external party, the company loses control over how that data is shared and interpreted by others.
Brent Carlson and Michael Huneke offer core principles that can guide the creation of a framework for mitigating these risks.
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