Red Flags Rising

Mike and Brent welcome Estelle Atkinson, a reporter with Global Investigations Review (GIR), to speak about her recent three-part series, “Fallen Chips,” published on January 26, 27, and 28, 2026 (linked in the show notes). They discuss how Estelle learned of the U.S. government investigation of Zenith Semiconductor in Chandler, Arizona (01:14); that company’s background (06:03); when employees started to realize that things were not quite right at the company and how that led to employees going to the FBI (08:19); how Estelle got to know the employees and why they were willing to help her with her story (10:30); how her experience illustrates more broadly the challenge companies have in responding to whistleblower reports or allegations (11:48); how diversion starts close to home, and is not always in some exotic “offshore” location (15:31); how U.S. administration policies to promote the export of the U.S. AI “stack” are not without controls or national security considerations (15:58); why success under America’s AI Action Plan and the American AI Export initiative will depend on effective, risk-based export controls compliance programs (16:21); the role of media in American life (19:14); why the standard PR or IR “playbook” of asserting “full compliance with the law” creates risks if companies aren’t expressly incorporating the full definition of “knowledge,” to include “an awareness of a high probability,” into export controls compliance (20:14); and what GIR readers can expect to see (or read) next from Estelle (20:49). Mike and Brent conclude with yet another installment of Brent Carlson’s “Managing Up” (22:39).
GIR: https://globalinvestigationsreview.com/
Fallen Chips Part I: Inside the FBI Raid that Rocked an Arizona Chip Start-Up (Jan. 26, 2026): https://globalinvestigationsreview.com/just-sanctions/article/fallen-chips-part-i-inside-the-fbi-raid-rocked-arizona-chip-start
Fallen Chips Part II: Silicon Secrets and the Risks Hiding in Plain Sight (Jan. 27, 2026): https://globalinvestigationsreview.com/just-sanctions/article/fallen-chips-part-ii-silicon-secrets-and-the-risks-hiding-in-plain-sight
Fallen Chips Part III: The Fault Lines of the US-China Tech War (Jan. 28, 2026): https://globalinvestigationsreview.com/just-sanctions/article/fallen-chips-part-iii-the-fault-lines-of-the-us-china-tech-war
More about Estelle: https://globalinvestigationsreview.com/authors/estelle-atkinson
Contact Estelle: [email protected]
Contact Brent: [email protected]
Contact Mike: [email protected]

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, they welcome her as a guest to talk about her specialties: national security, geopolitics, and corporate compliance. They specifically discuss Carole’s extensive professional background (00:59), a new treatise on National Security Law that Carole, Mike, and Brent are writing for the Practising Law Institute (PLI) (04:00), an upcoming event co-hosted by the New York State Bar Association’s International Section, Corporate Compliance Committee and Morgan Lewis, to which the new Assistant Secretary for Export Enforcement David Peters is an invited keynote speaker (08:18), why public enforcement officials remarks are relevant under U.S. export controls and other probability-based (i.e., “red flags”-driven) national security laws (09:26), how the U.S. Foreign Corrupt Practices Act (FCPA) was not only an example of that but also was really a child of an era where economic interdependency required a level of transparency and clean commerce to continue (12:00), and the relationship between Bretton Woods, Belt and Road, and Mike’s favorite book, Tales of an Economic Hitman, and what could be viewed with hindsight as effectively a U.S. policy decision to trade its own economic security for decades of (relative) world peace, increased global productivity, and increased living standards (16:52). Brent then closes out the discussion with the latest installment of his “Managing Up” segment (21:57), after which Mike makes some (further) book recommendations based on the discussion for those interested in further exploring some of the idea and concepts covered during the discussion:
Robert Lighthizer, No Trade Is Free: Changing Course, Taking on China, and Helping America's Workers (2023), https://www.amazon.com/No-Trade-Free-Changing-Americas/dp/0063282135
John Perkins, Confessions of an Economic Hitman (1st ed. 2004, currently on the 3rd ed. 2023), https://a.co/d/0fdEyBAg
W. Timothy Galloway, The Inner Game of Tennis (first published in 1972) (now a 50th anniversary edition is available), https://a.co/d/0hxybPKN
Daniel Kahneman, Thinking Fast and Slow (2011), https://a.co/d/03Q0vF0M
Michael Lewis, The Undoing Project (2016), https://a.co/d/09lcTL1M
More about Carole: https://www.linkedin.com/in/carole-basri-038998/
Contact Brent: [email protected]
Contact Mike: [email protected]
Interested in learning more about the March 10, 2026 event? Contact Mike & Brent at the email addresses above.

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 apply in practice as trade compliance professionals try to expect the unexpected in 2026. They discuss the importance of designing and implementing “compliance backstops” as geopolitical guardrails (01:47), how Stoic philosophy and the good work of Mo Bunnell (CEO and Founder of Bunnell Idea Group, author of Give to Grow) help build resiliency (03:40), review The Fraud Diamond Framework(SM) (05:57), describe how the framework can help trade compliance personnel to make and defend triage decisions (10:59), the implications of many trade compliance programs reaching a point in their evolution where they need to be able to demonstrate true integrity and effectiveness (13:45), the new 25% tariffs on certain semiconductors (14:38), and notable economic sanctions enforcement decisions related to lawyers’ advice or lawyers themselves (15:56). They conclude with Brent’s first Managing Up of 2026 (21:04).

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 Foreign Corrupt Practices Act. They discuss with Severin his inspiration for writing the book (02:44), the book’s focus on the people and personalities involved in the events between 1975 and the 1977 passage of the FCPA (05:50), the political and geopolitical scandals that kept up the momentum for a law banning overseas bribery (06:59), what his research uncovered beyond the traditional FCPA origin story (10:49), the relevance of the Cold War to the FCPA’s passage—specifically how corruption by capitalists fed into Communist propaganda (12:39), how the political “sausage” was made (16:33), stories of personal courage and risk-taking that made the FCPA possible (18:27), the use of the phrase “post-Watergate morality” as a critique of the FCPA and other reform efforts (21:48), how anti-corruption laws actually help American companies competing for business overseas (29:21), where the FCPA stands today (31:17), and how corruption is a social construct that, to paraphrase former federal appellate judge and author himself John Noonan, to exist as a legal concept must first exist in the minds of everyday people (35:40).
Mike and Brent then conclude with another installment of Brent Carlson’s “Managing Up” (38:14).
Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act—
Learn more at Corporate Compliance Insights here: https://www.corporatecomplianceinsights.com/bribery-beyond-borders-fcpa-severin-wirz/
Available at Amazon here: https://www.amazon.com/Bribery-Beyond-Borders-Foreign-Practices/dp/1735028592
More about Severin here: https://www.linkedin.com/in/severin-wirz-3574b574/
Contact Brent: [email protected]
Contact Mike: [email protected]

Mike & Brent explore the classic “Fraud Triangle” of pressure, opportunity, and rationalization and discuss Brent’s creation of a new “Fraud Diamond Framework” (SM) to help trade compliance (and other) professionals who are looking not to explain past misconduct but instead to prevent future misconduct. They discuss recent news and developments in the export controls world (00:55), how seemingly inconsistent headlines are actually consistent with each other (04:05), and how Edward Fishman’s “impossible triad” concept continues to be a useful tool for understanding what’s happening in geopolitics and trade competition (06:22), and then they launch into their discussion of Brent’s Fraud Diamond Framework (SM) (08:05).
Regarding the Fraud Diamond Framework (SM), they discuss the classic fraud triangle and the backward-looking perspective from which it was derived (09:18), and then explain the Fraud Diamond Framwork’s four elements of pressure (12:08), opportunity (13:06), something that’s too good to be true that comes at a critical time for the business (14:06), and signs of concealment (15:48). Brent next explains the Fraud Diamond Framework (SM) through a historical case study pulled from his own prior experience helping a client with a compliance commercial fraud dispute involving the acquisition of a business in China (17:35), after which they explain how the Fraud Diamond Framework (SM) can help trade compliance teams today (23:02).
They conclude with another installment of Brent’s always popular “Managing Up” segment (24:43).
Contact Brent: [email protected]
Contact Mike: [email protected]
“Chokepoints: American Power in the Age of Economic Warfare” by Edward Fishman: https://a.co/d/3Phvprs
Brent’s original NYU PCCE post, “When Loopholes Create Liability Pitfalls: A Fresh Look at Export Controls” (Aug. 25, 2023): https://wp.nyu.edu/compliance_enforcement/2023/08/25/29814/