Mike and Brent return with their take on a hotter-than-hot topic, the Bureau of Industry & Security’s new “50% Rule,” effective yesterday, September 29, 2025. Mike and Brent discuss the news of the rule’s announcement and the basics of what it does (00:46); the fact that the rule was effective immediately upon filing for public review, i.e., on September 29, 2025 (02:24); the fact that 50% is not some threshold under which risk goes away (06:19); how commentary suggesting that a “loophole” has been closed is not entirely accurate because such a loophole never existed in the first place (08:12); the requirements (including a description of due diligence performed) under a new, unique license application process (09:45); what enforcement risks are likely to arise in the government’s implementation of the new rule, especially if the government compares pre-rule trade flows to post-rule trade flows (10:43); the importance of not making a quick decision in how to respond to the new rule that you might later regret (12:23); the dangers of misreading the new rule to permit entity-shifting as an appropriate response (15:53); BIS’s caution that the rest of the U.S. Export Administration Regulations (EAR) still apply, separately from the Entity List (18:43); the admonition by BIS that “exporters, reexporters, and transferors have an affirmative responsibility to know the ownership of the foreign companies that are parties to a transaction” (19:45); the statement in the rule that those same actors “must adopt a risk-based compliance program to assist them in complying with these requirements” (20:14); the new “Red Flag 29” added to the BIS Know-Your-Customer (KYC) Guidance (21:05); and the importance of the explanatory text’s reference to “control” (irrespective of ownership) by a listed entity as a “red flag” requiring further due diligence (21:59).
Mike and Brent conclude with another installment, back by popular demand, of Brent Carlson’s “Managing Up” segment (24:57).
Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day, we consider four stories from the business world, including compliance, ethics, risk management, leadership, or general interest, relevant to the compliance professional.
Top stories include:
LRN named top compliance training provider. (Yahoo! Finance)
State of Texas to end ABA law school oversight. (Reuters)
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action against a Swiss-domiciled freight forwarding company, Fracht.
The case stands out for its complexity, involving a single, high-value transaction that exposed the company to significant sanctions risk through dealings with both Venezuelan and Iranian entities. Tom and Matt break down the compliance failures, the role of senior management, and the extensive remediation steps taken post-incident. This episode offers actionable lessons for compliance professionals on supply chain due diligence, the importance of compliance involvement in urgent deals, and the consequences of sidelining compliance functions.
Key highlights:
OFAC Enforcement Details
Anatomy of the Transaction
Third- and Fourth-Party Risks
Senior Management Involvement
Compliance Failures & Supply Chain Visibility
Remediation & Consequence Management
Key Takeaways for Compliance Professionals:
Always involve compliance in high-value, urgent transactions.
Ensure robust due diligence for all counterparties, including third- and fourth-party risks.
Senior management must be accountable for compliance failures.
Remediation should include policy updates, staff training, and ongoing oversight.
In this episode of From the Editor’s Desk, co-hosts Tom Fox and Ian Sherr dive into key compliance stories from July, including differences in AI regulation between the U.S., EU, and UK, and shifts in regulatory approaches globally. They discuss notable cases, such as the DOJ’s $14 billion healthcare fraud prosecution tied to transnational crime, and T-Mobile’s acquisition of US Cellular amidst DEI program cuts. Upcoming initiatives in Compliance Week are also highlighted, including in-depth industry coverage and data-driven stories to aid compliance professionals in their roles. The episode concludes with insights into the recent acquisition of ECI by Compliance Week’s parent company, Verdian Insights, which aims to enhance resources available to the compliance community.
Highlights include:
Highlighting Key Stories from Compliance Week in July
Emerging Patterns in Compliance
Tariffs and Their Impact
SEC Whistleblower Claims Analysis
Upcoming Features and Data Stories
ECI Acquisition by Verdian Insights and Its Impact
This episode focuses on geopolitical risk. In the initial spotlight segment, we speak with veteran journalist and Asia-watcher Christopher Cottrell about the military tensions in Thailand and their implications for the viability of the country’s newly proposed gaming law.
Following that, we chat with AML veteran Richard Butler of Dow Jones and data scientist Haider Mannan of BigTXN about the enforcement of the US Foreign Corrupt Practices Act, sanctions, and tariffs in the wake of recent actions by the Trump administration and the recent airstrikes on Iran.
Christopher Cottrell
Christopher Cottrell resides in Thailand and has been covering the Indo-Pacific region since 1997, contributing to publications such as The Boston Globe, Christian Science Monitor, CNN, The Guardian, Macau Business, The New York Times, and the South China Morning Post.
He spent 18 years in China and has been reporting on geopolitics in the Pacific Islands and Southeast Asia for the past four years, having edited UK-based Winna Media’s white papers on the Thai Entertainment Complex bill since 2024.
Richard Butler
Richard Butler is the vice president and APAC head of risk and research for Dow Jones & Co. Based in Sydney, Australia, he is responsible for helping businesses with risk and compliance strategies offsetting various forms of regulatory and commercial risk – such as the provision of high-quality, accurate and comprehensive data for identifying, evaluating and monitoring varying types of risk.
Before joining Dow Jones, Richard was the AVP for Treasury Services for Australia and New Zealand at JPMorgan Chase, where he was responsible for ensuring that JPMorgan’s financial institutional and non-bank financial institution clients in Australia and New Zealand adhered to JPMorgan’s best-in-class Know-Your-Customer, compliance, due diligence, and counter-terrorist financing standards. He began his career at ABN AMRO Bank, where he served as both the CAAML (Client Awareness and Anti-Money Laundering) officer and sales manager for the ABN AMRO Treasury Solutions Group in Dublin, Ireland.
Richard is skilled in governance, risk management, and compliance (GRC), as well as team management, direct sales, relationship building, and financial analysis, particularly in the APAC region.
Haider Mannan
Haider Mannan is the CEO and founder of BigTXN, a risk intelligence data provider. He is a data scientist and subject matter expert in investment screening, specializing in ESG controversies, global sanctions, and investment restrictions. He sits on the UK board of the Association of Certified Sanctions Specialists and the membership committee of the UK Sustainable Investment and Finance Association. Haider is also a member of PRMIA‘s advisory expert group on investment risk.
Discussion:
The conversation begins with Chris recounting the threats to Thailand’s security and stability, including the ongoing land border closure and standoff with Cambodia. He recounts with Regulatory Ramblings host Ajay Shamdasani that, notwithstanding its 22 prior coups, military rule, and reputation as a fragile democracy, Thailand has long been the darling of the global investment community, which has long touted its positive long-term economic fundamentals.
He adds the country has curried favor with the West by opening up in ways that many would regard as progressive, such as permitting the sale of cannabis products and paraphernalia, permitting same-sex unions, and seeking to liberalize its gaming sector by tendering a recent bill.
Yet, given the July 1 suspension by the country’s Constitutional Court of Prime Minister Paetongtarn Shinawatra over ethics violations and the weekslong border spat with Cambodia, which has been roiling fears of Thailand’s 23rd coup d’état, theimplementation of the new gaming law has been scuttled.
The discussion then shifts to Haider, who shares his thoughts on how data can help investment screening. He and Richard comment on how recent changes in the sanctions landscape, given the current geopolitical climate under the second Trump administration, pose a challenge for compliance and legal staff at banking and financial institutions, as well as multinational corporations.
Related to this are concerns about the implications for Asia regarding the extraterritorial enforcement of the much-dreaded US Foreign Corrupt Practices Act (FCPA) and the prospect of tariff imposition by the White House, as well as the potential for regulatory retaliation by other countries.
It’s worth noting that on June 9, Matthew Galeotti, head of the US Department of Justice’s (DOJ) criminal division, saidthat under new FCPA guidelines now in place, it would enforce the Act Firmly but fairly.” The comments followed President Trump’s announcement earlier this year that the DOJ would hold off on FCPA enforcement following a review of current standards, as it was believed the existing regulatory regime put US businesses at a disadvantage when competing abroad.
Haider and Richard also discuss why geopolitics matter and the need for lawyers and risk managers to go beyond merely tracking financial news. The conversation concludes with a discussion of a recent case in which the US DOJ’s Office of Foreign Asset Control (OFAC) sanctioned entities/companies in Hong Kong and mainland China that were involved in transferring Iranian oil to China.
Regulatory Ramblings podcasts is brought to you by The University of Hong Kong – Reg/Tech Lab, HKU-SCF Fintech Academy, Asia Global Institute, and HKU-edX Professional Certificate in Fintech, with support from the HKU Faculty of Law.
Mike and Brent follow up on Mike’s being quoted in the Dow Jones Risk Journal regarding the unexpected export control consequences of the Israel-Iran conflict. They discuss the geopolitical context (00:39), the article by Richard Vanderford and Mengqi Sun (01:22), the risk that Iran tries to evade U.S. export controls (and sanctions) by procuring replacement parts and equipment through third-party intermediaries (02:12), the cautionary tale of an Alabama resident sentenced to five years in U.S. federal prison for diverting items to Iran (03:29), the need to be cognizant of “catch-all” U.S. export controls related to ballistic missiles and WMD programs (including nuclear) and those controls reliance on the full definition of “knowledge” to include “an awareness of a high probability” (04:42), increased tracking and investigative activity by the U.S. government (06:19), how companies need to think about responding to “red flags” (06:45), the likely impact of forensic review of battlefield recoveries on requests by Israel and NGOs to companies for assistance in tracing item or component flows to Iran (07:44), and the likelihood of increased, rather than decreased, activity by U.S. agencies as a result of the conflict (09:52). They conclude with another segment of Brent Carlson’s “Managing Up” (12:26).
This episode begins with a brief spotlight chat with Lucas Har from Dow Jones in Singapore, discussing trade compliance, sanctions, dual-use goods, and supply chain risk, particularly in the context of the currently strained US-China trade relationship following the recent increase in US tariffs on China and Hong Kong.
We then proceed to a discussion with Hong Kong-based Joshua Chu and Melizza Anievas to explore Hong Kong’s recently enacted Stablecoin Ordinance, including the distinction between meme coins and stablecoins, as well as the ever-evolving global landscape for virtual assets in light of recent regulatory developments in the US.
On May 21, 2025, the Hong Kong Legislative Council passed the Stablecoins Ordinance, creating a formal licensing regime for fiat-referenced stablecoin (FRS) issuers. While local in implementation, the regulatory milestone decisively places Hong Kong at the forefront of a broader Asian effort to shape the future of legitimate, rules-based decentralized finance (DeFi) and tokenized financial infrastructure.
The move came just one day after the US Senate passed the GENIUS Act. Against this backdrop, Hong Kong’s move added momentum to global harmonization efforts on stablecoin regulation, directing the policy debate more towards developing trustworthy digital asset ecosystems with practical, real-world utility and functionality.
The territory’s new framework requires all issuers promoting fiat-backed stablecoins to the general public locally to be licensed by the Hong Kong Monetary Authority (HKMA)—the city’s banking regulator and de facto central bank.
Additionally, issuers must hold reserves in either cash or high-quality, highly liquid assets, such as short-term government securities. Stablecoins must be redeemable at par value at any time. Issuers must regularly disclose their reserve holdings and undergo audits. AML/CFT compliance and risk controls are also required.
This regulatory clarity is paired with active development. For example, Hong Kong’s Stablecoin Sandbox, launched last year, has enabled companies such as Standard Chartered, Animoca Brands, and JD Coinlink to test real-world use cases across payments, capital markets, and trade finance. Ultimately, it reflects a coordinated effort to turn policy into practical rails for tokenized activity.
Joshua Chu
Joshua Chu is a prominent Hong Kong lawyer specializing in fintech and crypto matters, as well as a prolific writer. His opinion and insights are much sought after by the local press and correspondents of major foreign news organizations operating in the city. You can often hear him at his most candid on the radio at RTHK.
Joshua is also co-chair of the Hong Kong Web 3 Association and legal advisor to the Hong Kong Blockchain Association.
Melizza Anievas
Melizza Anievas is a co-founder and executive director of Women in Web3 Hong Kong. Under her leadership, Women in Web3 Hong Kong has grown to over 1,500 members and secured over HK$300,000 in sponsorships within a year, establishing working relationships with notable partners such as Google Cloud Hong Kong, The Sandbox, and Animoca Brands. A Web3 veteran since 2019, Melizza excels at devising growth-driven strategies and operating hyper-growth businesses.
Lucas Har
Lucas Har is based in Singapore and has been with Dow Jones Risk & Compliance for nearly a decade. He began his career with a focus on Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) research across a diverse portfolio of Asia-Pacific jurisdictions.
Later, Lucas took on a leadership role overseeing the company’s content curation team, where he was responsible for news curation and monitoring adverse media.
In his current position, he manages the firm’s global trade compliance product suite, spearheading innovation and strategic growth.
He has also extensively engaged with financial institutions, corporations, and regulators across multiple regional jurisdictions, fostering discussions on export control compliance and further strengthening Dow Jones’s expertise in such an increasingly vital and complex area.
Discussion:
As our guests flesh out, several common threads emerge linking the two segments of today’s episode. The first is that of regulatory fragmentation across jurisdictions such as the US, mainland China, Hong Kong, and the EU.
There is also the issue of extraterritorial overreach and competition, particularly between China’s export rules and US crypto laws, as well as a global push for clarity in fast-moving, high-risk sectors, including the international trade of goods and virtual assets more broadly. Simply put, the heavy geopolitical undertones in both export control and digital asset regulation cannot be avoided, as they cast a shadow on the role of trust and credibility, or the lack thereof, in navigating both trade and cryptocurrency systems.
With that in mind, the podcast begins with Regulatory Ramblings host Ajay Shamdasani asking Lucas about the evolving regulatory landscape shaping international trade and its implications for Hong Kong businesses, as well as the impact of mainland China’s new export control regulations on dual-use goods.
Lucas shares what legal and compliance specialists need to know about the regulatory hurdles the firms they serve must adhere to, including sanctions and export control regulations, as well as best practices for enhancing due diligence procedures to mitigate trade-related risks.
Following that, Joshua and Melizza share their thoughts on what the new stablecoin ordinance will mean for Hong Kong, as well as the importance of recent US regulations. Securities and Exchange Commission clarifications on meme coins and their potential impact on legal, risk, and compliance strategies for developers and investors.
The three of them go on to discuss the key operational and regulatory challenges stablecoin issuers face under Hong Kong’s new licensing regime and how the US GENIUS and STABLE Acts might reshape the US stablecoin market and influence global regulatory approaches.
Indeed, something worth asking—and which Joshua and Melizza do not shy away from commenting on — is whether the relatively ‘light touch’ regulation of meme coins encourages innovation or exposes investors to undue risk.
The conversation concludes with a chat about how projects can effectively balance innovation with regulatory compliance amid differing US and APAC frameworks. Most memorable is how Melizza distinguishes between Web 3.0 and Web3.
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 (00:00), the guidance from BIS on General Prohibition 10 and Huawei Ascend chips (03:34), the related BIS policy statement (04:13), and then focus on the BIS “Industry Guidance to Prevent Diversion of Advanced Computing Integrated Circuits” (04:47), specifically the underlying U.S. national security concerns (05:50), relevant key takeaways from Episode 13’s special guest Dana W. White (06:51), the significance of the Industry Guidance’s reference to the WMD and military-intelligence catch-all provisions (08:29), the historical pre-1993 “KYC Guidance” cross-referenced by BIS in the new Industry Guidance (11:53), how the historical “KYC Guidance” is often misunderstood through selective quotation devoid of relevant context (13:34), the new “red flags” identified in the May 13, 2025 Industry Guidance (16:10), the key takeaways of the Industry Guidance (17:55), a warning about over-reliance on the Industry Guidance’s statement about existing end-use certificates (18:47), and the practical implications of the Industry Guidance for trade compliance teams (19:36). They then conclude with the next installment of Brent Carlson’s “Managing Up” (21:26).
Mike & Brent return with a point-counterpoint episode on U.S. export control policy. After discussing the latest news about U.S. AI export controls (01:03), they discuss the points and counterpoints related to whether we should have export controls at all (04:57), the relevance of the national security justifications offered by the U.S. Department of Commerce in promulgating its regulations (06:52), the lessons of Ukraine battlefield recoveries (09:59), the views of Anthropic’s CEO, Dario Amodei, on risk and how to push any industry to a more-compliance mindset (rather than acquiesce to the race to the bottom) (10:44), why Brent shouldn’t talk about the old days of corruption (12:08), and how not only the export controls’ design but also their enforcement by government and compliance efforts by industry are all relevant factors to consider in assessing export controls’ effectiveness (14:53). They conclude with the latest installment of Brent’s “Managing-Up” segment (23:04).
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this Compliance into the Weeds episode, Tom Fox and Matt Kelly take a deep dive into the declination recently given by the DOJ to the Universities Space Research Association (USRA).
In this episode, Tom and Matt dive deeply into a recent decline issued by the Department of Justice (DOJ) to the University Space Research Association (USRA). The discussion focuses on the organization’s exemplary behavior in self-disclosure and cooperation during an investigation into an employee’s misconduct. This misconduct included unauthorized export of software to Beijing University. The hosts highlight the case as a textbook example of effective compliance practices, self-reporting, and cooperation with regulators. They also explore the DOJ’s guidelines on self-disclosure and the importance of internal controls in high-risk areas.
Key highlights:
Case Overview: USRA Declination
DOJ Press Release Insights
Details of the Misconduct
USRA’s Response and Cooperation
Resources:
DOJ Press Release on Universities Space Research Association Declination
