It May Not Be Worth the Paper (or Pixel) It’s Written On (pt. 2)
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A Fresh Look at Common Responses to Bolster Export Controls Compliance Programs as BIS Primes the Corporate Enforcement Engine
Guidance issued by the US Bureau of Industry and Security (BIS) has primed the corporate enforcement engine with a new strategy that parallels the Foreign Corrupt Practices Act (FCPA) enforcement playbook. This change increases challenges—and opportunities— for in-house legal and compliance teams to bolster compliance program effectiveness.
Brent Carlson and Michael Huneke examine common responses based on legacy assumptions and approaches to export controls; and explain why they are ineffective—and even detrimental—in today’s evolving enforcement environment.
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