Red Flags Rising
Episodes
"Fallen Chips" - GIR's Estelle Atkinson on her Three-Part Report
03 Mar 2026
Contributed by Lukas
Mike and Brent welcome Estelle Atkinson, a reporter with Global Investigations Review (GIR), to speak about her recent three-part series, “Fallen Ch...
Carole Basri on Subsidizing World Peace: the U.S. Experiment, and the Dynamic Relationship between National Security & Corporate Compliance
20 Feb 2026
Contributed by Lukas
Back in January 2024, Mike and Brent had the good fortune to meet Carole Basri at an event at NYU Law School. On this episode of Red Flags Rising, the...
How to Prepare for 2026 - The Fraud Diamond Framework (SM) Applied
28 Jan 2026
Contributed by Lukas
Mike and Brent return for the new year with a refresher on The Fraud Diamond Framework(SM) introduced in Episode 34 and an explanation of how it would...
Origins & Parallels - The FCPA and U.S. Export Controls, Yesterday and Today, with Severin Wirz
29 Dec 2025
Contributed by Lukas
Mike and Brent welcome author and compliance professional Severin Wirz to the pod to discuss his first book, Bribery Beyond Borders: The Story of the ...
Introducing Brent Carlson's Fraud Diamond Framework (SM)
18 Dec 2025
Contributed by Lukas
Mike & Brent explore the classic “Fraud Triangle” of pressure, opportunity, and rationalization and discuss Brent’s creation of a new “Fra...
Back to Basics
02 Dec 2025
Contributed by Lukas
As the geopolitical and national political winds continue to swirl, Mike & Brent go back to basics to level-set and provide some foundational firs...
Don’t Wait for Godot - Seize Control with Your Own Compliance Clarity
11 Nov 2025
Contributed by Lukas
Mike & Brent draw inspiration from the current Broadway run of Waiting for Godot starring Keanu Reeves and Alex Winter to suggest some first princ...
Running To and Through the Export Controls Investigation Finish Line - Avoiding Resolution Pitfalls and Monitoring What Matters
03 Nov 2025
Contributed by Lukas
Mike and Brent take a break from Affiliates Rule (delayed) suspension news to focus on practical advice for companies that might be in the middle of U...
Look Before You Leap, Think Before You Speak
20 Oct 2025
Contributed by Lukas
Fresh off the October 15, 2025, WIT-NC/PAEI/TTRA “Global Trade Compliance Best Practices Conference” in Santa Clara, California, Mike and Brent di...
Affiliates Rule Aftermath – Finding the Right Path Forward
07 Oct 2025
Contributed by Lukas
Mike and Brent take an even deeper dive into the “Affiliates” or “50%” Rule announced by the Bureau of Industry & Security (BIS) on Septem...
The Long-Awaited "50% Rule" - Key Takeaways and Liability Pitfalls to Avoid
30 Sep 2025
Contributed by Lukas
Mike and Brent return with their take on a hotter-than-hot topic, the Bureau of Industry & Security’s new “50% Rule,” effective yesterday, S...
Open One Eye, Close One Eye
25 Aug 2025
Contributed by Lukas
Mike & Brent break down the investigative report by the Editor-in-Chief of Gamers Nexus, Steve Burke, and his colleagues into GPU smuggling into C...
Grab the Carrots, Avoid the Sticks, and Get Ready for More Transparency
25 Aug 2025
Contributed by Lukas
Mike and Brent pick up the discussion from Episode 25 with some further thoughts on the proposed revenue-sharing arrangement between the U.S. governme...
Deals, More Deals, and Protective Backstops
14 Aug 2025
Contributed by Lukas
Mike & Brent dive into the latest geopolitical developments surrounding technology exports and the interplay between leading tech companies and th...
Preventing Diversion Starts Close to Home
10 Aug 2025
Contributed by Lukas
Mike and Brent break down the key takeaways from an affidavit by a Bureau of Industry & Security Special Agent in Los Angeles, which was unsealed ...
$140M "High Probability" Enforcement Action
01 Aug 2025
Contributed by Lukas
Mike and Brent breakdown the $140 million corporate resolution announced on Monday, July 28, 2025, by the U.S. Department of Commerce’s Bureau of In...
All-In on America's AI Action Plan
28 Jul 2025
Contributed by Lukas
Mike and Brent go All-In regarding America’s AI Action Plan, unveiled by the White House on Wednesday, July 23, 2025, and discussed in detail at a f...
"Secondary Tariffs" with Tom Fox
23 Jul 2025
Contributed by Lukas
Mike and Brent were honored guests on the FCPA Compliance Report podcast with their podfather, Tom Fox, the Voice of Compliance and founder of the Com...
China, AI, and Export Controls - Facing a Moment of Truth
20 Jul 2025
Contributed by Lukas
Mike and Brent follow-up on Episode 19’s discussion of “stack sweeps” with a discussion of the current “moment of truth” facing trade compli...
Stack Sweeps, Successor Liability, and “Knowledge” – Emerging Signals from Recent Enforcement Actions
11 Jul 2025
Contributed by Lukas
Mike & Brent coin a new phrase in the context of white-collar corporate enforcement, “stack sweep,” to describe the potential enforcement risk...
FRESH LOOKS - Monitoring What Matters
29 Jun 2025
Contributed by Lukas
Mike and Brent propose a new framework for post-resolution third-party independent consultants imposed under corporate resolutions with the U.S. Burea...
Data-Driven Root-Cause Analysis with Erika Trujillo of SEIA
21 Jun 2025
Contributed by Lukas
Mike & Brent welcome Erika Trujillo, Managing Director of SEIA (“say-a”), who with her company brings advanced data analytics solutions to sol...
The Israel-Iran Conflict's Implications for U.S. Export Controls
18 Jun 2025
Contributed by Lukas
Mike and Brent follow-up on Mike’s being quoted in Dow Jones Risk Journal regarding the unexpected export control consequences of the Israel-Iran co...
Tom Blass of WorldECR Magazine & Dow Jones on Bridging the Law/Geopolitics Divide and Building Communities
10 Jun 2025
Contributed by Lukas
Mike and Brent welcome Tom Blass, Editorial Director of World Export Controls Review (WorldECR) Magazine that is now part of Dow Jones. Mike and Brent...
Getting a Grip on U.S. Export Controls Guidance
31 May 2025
Contributed by Lukas
Mike and Brent unpack the May 13, 2025, due diligence guidance from the U.S. Bureau of Industry & Security. They describe what happened on May 13 ...
Dana W. White on U.S. National Security & Export Controls
29 May 2025
Contributed by Lukas
Mike and Brent welcome Dana W. White, Managing Partner at the Juno Collective, to share her thoughts and analysis regarding China and U.S. export cont...
End-Use and End-User Catch-Alls
13 May 2025
Contributed by Lukas
In a timely episode discussing end-use and end-user controls and how the full definition of “knowledge”--to include “an awareness of a high prob...
Point-Counterpoint - U.S. Export Controls Policy
12 May 2025
Contributed by Lukas
Mike & Brent return with a point-counterpoint episode on U.S. export control policy. After discussing the latest news about U.S. AI export control...
AI Diffusion: A Proposed Path for Industry & Government
01 May 2025
Contributed by Lukas
Mike & Brent propose an AI Diffusion Rule path forward to help both companies and the U.S. government. They start with an update on last-minute re...
Tariffs: Navigating Uncertainty & Mitigating Enforcement Risk
24 Apr 2025
Contributed by Lukas
Mike & Brent jump into tariffs to focus on practical strategies to navigate these uncertain times and to mitigate the risk of future enforcement a...
Responding to Congressional Inquiries
17 Apr 2025
Contributed by Lukas
Mike & Brent react to recent media reports of several congressional committees demanding information from U.S. companies. They revisit their March...
Clarity from Chaos: U.S. Export Controls Enforcement Signals & What to Do About Them
15 Apr 2025
Contributed by Lukas
Mike & Brent connect the dots between the Administration's signals regarding U.S. export control enforcement, recent media reports, and how trade ...
FRESH LOOKS - Export Controls Risk Assessments
11 Apr 2025
Contributed by Lukas
Mike & Brent return to their prior "Fresh Looks" series to highlight their September 28, 2023, post on NYU Law School's Program on Corporate Compl...
The Knowledge "Glass Onion" for U.S. Export Controls
08 Apr 2025
Contributed by Lukas
Mike & Brent update listeners on the America First Trade Policy Section 4(c) Report Executive Summary (01:05) before previewing their forthcoming ...
FRESH LOOKS - Export Controls Penalties
03 Apr 2025
Contributed by Lukas
In Episode 4, Mike and Brent revisit another of their prior "Fresh Looks" posts on the NYU Law School's Program on Corporate Compliance & Enforcem...
FRESH LOOKS - Loopholes and Liability Pitfalls
21 Mar 2025
Contributed by Lukas
Mike & Brent revisit Brent's original August 25, 2023, "Fresh Looks" post, "When Loopholes Create Liability Pitfalls: A Fresh Look at Export Contr...
Lutnick: "We Have Had Enough"
18 Mar 2025
Contributed by Lukas
Mike and Brent discuss remarks at the Bureau of Industry & Security's "Update" Conference that started today in Washington, DC (00:00), specifical...
DeepSeek's Deep Impact on Export Controls
14 Mar 2025
Contributed by Lukas
In the launch of Red Flags Rising, Mike and Brent explain the concept and purpose of the pod (00:00), a recent report by Gregory C. Allen of the Cente...
Teaser Trailer
14 Mar 2025
Contributed by Lukas
Teaser trailer for the new Red Flags Rising podcast!