Part 1 of this series walked through the settlement terms and the sheer range of violations DDTC documented against BAE Systems, spanning unlicensed technical data exports, unauthorized defense services, agreement mismanagement, and documentation failures. In Part 2, we focus on what actually caused all of this, because DDTC’s charging letter is unusually candid about root causes, and those root causes are far more instructive than...

If your organization does not yet have a written AI Acceptable Use Policy, I can tell you exactly what is happening inside your walls right now: employees are already using AI tools, whether you have authorized it or not. They are pasting documents into chatbots to summarize them, asking generative AI to draft correspondence, running research queries, and increasingly relying on AI features quietly embedded...

Part 1 of this series laid out why the risk landscape around generative AI, confidentiality exposure, hallucination risk, and vendor risk, makes a written AI Acceptable Use Policy an urgent priority rather than a nice-to-have. In Part 2, I want to walk through what actually needs to be in that policy for it to function as a real governance tool rather than a document nobody...

Reuters reported this week that the Federal Trade Commission has opened an antitrust investigation into Epic Systems, the dominant electronic health records vendor based in Verona, Wisconsin. The report, citing two sources familiar with the matter, says the FTC has already sent investigative demands to other companies in the health technology industry, seeking information about how Epic controls access to patient data. The agency has...

The Bureau of Industry and Security’s Fiscal Year 2025 Annual Report to Congress is not a routine bureaucratic filing. It reads more like a mission statement, and the numbers inside it back up the rhetoric. Export control enforcement has escalated dramatically over the past year, and companies operating in semiconductors, aerospace, defense, dual-use technology, and cross-border trade more broadly need to understand exactly how much...

The State Department’s Directorate of Defense Trade Controls just handed down a $36 million penalty against BAE Systems, Inc., resolving more than 100 alleged violations of the International Traffic in Arms Regulations and the Arms Export Control Act stretching from 2019 through as recently as March 2025. This is Part 1 of a two-part series on the case. Here, we walk through the settlement structure...