The Trump Administration’s handling of antitrust enforcement issues is generally viewed as a wild-card — meaning there are issues of concern or focus that may not fit the “traditional” antitrust enforcement model. Depending...more
9/3/2025
/ Antitrust Division ,
Antitrust Investigations ,
Big Tech ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Hart-Scott-Rodino Act ,
Leniency Programs ,
Merger Reviews ,
Mergers ,
Pharmaceutical Industry ,
Price-Fixing ,
Trump Administration
With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement...more
9/3/2025
/ Compliance Monitoring ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Sanction Violations ,
Sanctions ,
Supply Chain ,
Third-Party Risk
With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement...more
Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed -...more
Given the real and significant potential benefits of AI, companies have to be careful in the rush to implement AI technology. Starting with a clear use case, companies have to weigh the potential benefits of AI technology and...more
8/18/2025
/ AI Act ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
EU ,
Export Controls ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Healthcare ,
New Legislation ,
Regulatory Requirements ,
Risk Management
The new world of AI presents significant benefits and risks that need to be addressed in an overall governance framework. Luckily, the principles to apply here will surprise no one — governance, compliance, legal and risk...more
8/14/2025
/ Artificial Intelligence ,
Automated Decision Systems (ADS) ,
Best Practices ,
Bias ,
Board of Directors ,
Compliance ,
Data Privacy ,
Data Security ,
Governance Standards ,
Incident Response Plans ,
Policies and Procedures ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation
Well, let’s all admit it — we have all enjoyed using the new, hot technology, AI. It is an understatement to opine that AI is transforming our world, business and personal. This development compares to the 1990s and the...more
8/14/2025
/ AI Act ,
Artificial Intelligence ,
Bias ,
Data Privacy ,
Data Protection ,
Deep Fake ,
Discrimination ,
Federal Trade Commission (FTC) ,
Intellectual Property Protection ,
Regulatory Requirements ,
Risk Management ,
State Privacy Laws
In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects...more
Last week, the Justice Department announced that Cadence Design Systems Inc. (Cadence), a global electronic design automation (EDA) technology company based in San Jose, California, agreed to plead guilty to a conspiracy to...more
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?
In this episode, Michael dives into the DOJ’s...more
What happens when a company tries to outsmart the system - and gets caught red-handed by the DOJ in a $140 million export control scheme tied to Chinese military supercomputers?
In this episode, Michael dives into the DOJ’s...more
Well, we are in a new era — a fundamental change has occurred, long in the making. National security and trade enforcement have coalesced to elevate trade risks — sanctions and export controls violations will be prosecuted...more
8/7/2025
/ Bureau of Industry and Security (BIS) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Due Diligence ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Training
Criminals are not as smart as they think they are. There is nothing so unique that elevates a scheme into the ethereal world of brilliance. The schemes get to be “typical” and the means by which they are executed are often...more
DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA...more
8/5/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Entity List ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Intellectual Property Protection ,
International Trade ,
National Security ,
PRC ,
Risk Management ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
NAVEX dominates the hotline market. Given its global footprint, NAVEX has access to a large database of employee reports. Building on this unique perspective, NAVEX provides an annual report analyzing the employee reporting...more
8/4/2025
/ Annual Reports ,
Benchmarking ,
Best Practices ,
Compliance ,
Corporate Governance ,
Data Collection ,
Data Privacy ,
Data Reporting ,
Hotlines ,
Incident Response Plans ,
Internal Reporting ,
Reporting Requirements ,
Risk Management ,
Whistleblower Hotlines ,
Whistleblowers
Is your internal reporting program keeping up or falling behind the curve?
With over 2.15 million reports analyzed from nearly 70 million employees worldwide, NAVEX's 2025 Regional Whistleblowing & Incident Management...more
NAVEX dominates the hotline market. Given its global footprint, NAVEX has access to a large database of employee reports. Building on this unique perspective, NAVEX provides an annual report analyzing the employee reporting...more
7/29/2025
/ Compliance ,
Corporate Governance ,
Employee Rights ,
Employment Policies ,
Ethics ,
EU ,
Internal Reporting ,
Reporting Requirements ,
Retaliation ,
Risk Management ,
Whistleblowers ,
Workplace Safety
The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more
7/28/2025
/ Consumer Protection Laws ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Evasion ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Investigations ,
Tariffs ,
Trade Policy ,
Trump Administration
A competitor could trigger a federal investigation against your company, just by filing a whistleblower complaint about your imports.
In this episode, Michael Volkov explores how the Trump Administration is reshaping the...more
The ethics and compliance field has been tested during the transition to the Trump Administration. Some have held on to the mantra — No Change — to respond to the changes in the role of the federal government, enforcement...more
7/23/2025
/ China ,
Compliance ,
Corporate Governance ,
Enforcement Priorities ,
Ethics ,
Imports ,
International Trade ,
Risk Management ,
Tariffs ,
Trump Administration ,
US Trade Policies
Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate...more
7/22/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Financial Crimes ,
Money Laundering ,
Risk Management ,
Significant Transnational Criminal Organization ,
Supply Chain
The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more
7/22/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Cuban Assets Control Regulations (CACR) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Huawei ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury
What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws?
In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more
DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __...more
7/17/2025
/ China ,
Court of International Trade ,
Customs ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Investigations ,
Jurisdiction ,
Penalties ,
Tariffs ,
US ex rel Tracy Schutte et al v SuperValu Inc et al ,
Whistleblowers
The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more
7/16/2025
/ Anti-Dumping Duty ,
Customs ,
Department of Justice (DOJ) ,
Duties ,
Enforcement ,
Enforcement Actions ,
Evasion ,
False Claims Act (FCA) ,
Fraud ,
Imports ,
International Trade ,
Penalties ,
Section 301 ,
Tariffs ,
Whistleblowers