A Primer on Trade Controls for Compliance Professionals: Which Companies Are at Risk, Anti-Corruption Report
October 07, 2026Partner Michael Huneke spoke with Anti-Corruption Report for the third installment of its four-part series on trade controls, focusing on the broad reach of US trade restrictions and the compliance risks facing companies across industries.
Mike explained that trade controls can apply not only to companies directly engaged in international trade but also to third parties facilitating transactions. He emphasized that the broad definition of knowledge under certain trade control regimes means companies may face liability when they are aware of a high probability of a violation.
“That broad definition of knowledge is really the new national security paradigm,” he said.
Michael also noted that the growing use of the False Claims Act in tariff enforcement creates additional whistleblower risks, including the possibility of competitors reporting suspected tariff evasion in pursuit of financial recoveries.
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