The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight. The Justice Department played a critical role in coordinating international efforts and enforcement. in the...more
4/29/2025
/ Anti-Corruption ,
Bribery ,
California ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
Switzerland ,
UK
Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more
As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and...more
4/25/2025
/ Audits ,
Compliance ,
Data Privacy ,
Data Security ,
Deadlines ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement ,
New Regulations ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding. The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more
How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more
Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more
4/18/2025
/ Compliance ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
Executive Orders ,
Export Controls ,
National Security ,
New Regulations ,
Personal Data ,
Prohibited Transactions ,
Regulatory Requirements ,
Sensitive Personal Information
The Trump Administration is focused on change in the government’s role, the administrative state, and the political environment. With these changes, you can expect the Trump Administration to aggressively pursue violators —...more
Chief compliance officers are adjusting a new, risk world, where top risks include export controls, sanctions, and immigration enforcement. At the same time, some risks remain — third-party risks, conflict of interest, fair...more
3/25/2025
/ Chief Compliance Officers ,
Compliance ,
Department of Justice (DOJ) ,
Export Controls ,
Imports ,
International Trade ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
Tariffs ,
Third-Party Risk ,
Trump Administration
When assessing your third-party risks, it is important to start with one important division — a company’s supply chain and on the flip side, a company’s distribution chain. Sourcing materials and supply chain links present a...more
3/19/2025
/ Anti-Corruption ,
Anti-Money Laundering ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Distributors ,
Due Diligence ,
Financial Crimes ,
Human Trafficking ,
Risk Management ,
Supply Chain
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to...more
2/25/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cartels ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
SDN List ,
Supply Chain
Are You Ready for the Next Wave of Corporate Risk?
Corporate risks are shifting, and every board, C-suite, and compliance team must take a fresh look at their risk landscape.
While some risks like cybersecurity, data...more
We live in a topsy-turvy world. This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has...more
2/18/2025
/ Anti-Corruption ,
Antitrust Division ,
Competition ,
Compliance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Foreign Corrupt Practices Act (FCPA) ,
Human Resources Professionals ,
Immigration Enforcement ,
International Trade ,
Risk Assessment ,
Risk Management ,
Trump Administration
What happens when an entire era of anti-corruption enforcement is put on pause?
Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability?
In an unprecedented move, the...more
The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer. When cooler heads prevail, it is much easier to pick through the...more
2/14/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling. In some respects, we have had a preview. It is hard to know what...more
2/12/2025
/ Anti-Corruption ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
OECD ,
Regulatory Agenda ,
Regulatory Freeze ,
RICO ,
White Collar Crimes
What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more
2/12/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Regulatory Agenda ,
Trump Administration
In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice. The White House’s announcement seemed to...more
In an unprecedented and surprising set of actions, the new Attorney General Bondi issued eleven new, internal directives for the Department of Justice. The new Directives are available HERE. Immediately after her...more
2/11/2025
/ Affirmative Action ,
Civil Rights Act ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Executive Orders ,
Race Discrimination ,
Regulatory Agenda ,
Regulatory Reform ,
Sex Discrimination ,
Trump Administration ,
Whistleblower Protection Policies ,
Whistleblowers
In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and...more
1/28/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025?
Will the push for innovation in corporate compliance programs be enough to maintain...more
Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more
1/22/2025
/ Anti-Corruption ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
White Collar Crimes
While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies. These measures were believed to coincide with a number of significant...more
How will your company withstand the heat of aggressive sanctions enforcement? Are you ready for the DOJ’s new priorities and OFAC’s expanding reach in 2025?
In this episode of Corruption, Crime, and Compliance, Michael...more
Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more
1/16/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Third-Party Risk ,
White Collar Crimes
With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement. On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more
1/16/2025
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Penalties ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes