Overview
The Anti-Corruption Report quoted Andrew Adams in an article titled, "Are Recent Export Controls Enforcement Actions Low-Hanging Fruit or a New Wave of Prosecutorial Zeal?" The article discusses recent DOJ enforcement actions targeting individuals who violated export controls laws by shipping products to Russia and if they are part of a more aggressive – and coordinated pursuit of bad actors.
Speaking to The Anti-Corruption Report about these enforcement actions, Adams said: "A key lesson is that the size of a counterparty or the volume of trade that they represent are not the sole criteria on which to judge a potential threat." Companies "need to be on the look-out for aberrant patterns of trade or mismatches between a counterparty's public face and the activity they engage in privately," which is "a data management and pattern recognition problem, and therefore a problem that requires companies to stay up to date on state-of-the-art technology designed for exactly this kind of screening."
Read the full article in The Anti-Corruption Report (Subscription Required).
