A Fresh Look at the “Willful” Intent Standard for Criminal Liability in Export Controls and Sanctions Corporate Enforcement
BRG is home to renowned thought leaders and experts considered authorities in their fields of work. Our timely research and perspectives provide analysis and insights on the most important issues facing the industries and organizations we serve.
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.
Related Professionals
Prepare for what's next.
ThinkSet magazine, a BRG publication, provides nuanced, multifaceted thinking and expert guidance that help today’s business leaders adopt a more strategic, long-term mindset to prepare for what’s next.