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
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
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
7/13/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Cartels ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Financial Crimes ,
Risk Management ,
Supply Chain
Cartels and TCOs have entrenched themselves in legitimate industry sectors. In recent years, cartels and TCOs have adapted to market changes and new technologies. Many cartels and TCOs are disguising their ownership and...more
Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal...more
The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more
Is AI a magic bullet - or just another tool in the compliance toolkit?
What really happens when you let algorithms near your risk decisions?
In this episode of Corruption, Crime and Compliance, Christian Focacci, founder...more
6/15/2025
/ Algorithms ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Due Diligence ,
FinTech ,
Innovative Technology ,
Legal Technology ,
Machine Learning ,
Risk Management ,
Technology
LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This...more
5/6/2025
/ Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Due Diligence ,
Emerging Technologies ,
Employee Training ,
Ethics ,
Generation Z ,
Risk Management ,
Third-Party Risk
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
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
Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime. OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more
9/26/2024
/ Audits ,
Compliance ,
Cosmetics ,
Due Diligence ,
Enforcement Actions ,
Goods or Services ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Suppliers ,
Supply Chain
It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason —...more
The past two years brought heightened scrutiny to supply chain risks and human rights violations, and time is running out to ensure your organization is compliant with the recent regulation updates and policy...more
2/19/2024
/ Business Operations ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
EU ,
Human Rights ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Supply Chain ,
Sustainability ,
Transparency ,
Webinars
Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group,...more
3/28/2023
/ Bribery ,
Compliance ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Foreign Acquisitions ,
Foreign Corrupt Practices Act (FCPA) ,
Online Gaming ,
Russia ,
Securities and Exchange Commission (SEC) ,
Sports Betting ,
White Collar Crimes
The Covid-19 pandemic and Russia’s aggression in Ukraine have disrupted supply chains and heightened the need for supply chain due diligence to ensure business continuity and sustainability. Coupled with these events are...more
6/21/2022
/ Corporate Liability ,
Corporate Social Responsibility ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Modern Slavery Act ,
Popular ,
Regulatory Agenda ,
Risk Management ,
Supply Chain ,
Transparency in Supply Chains Act ,
Uyghur Forced Labor Prevention Act (UFLPA)
It is an initially daunting task — identify all of your third-party partners with whom your company conducts business. For large global companies, this is no easy issue. Some companies do not have readily available a list...more
Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more
2/24/2022
/ Bribery ,
C-Suite Executives ,
Corporate Misconduct ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Political Contributions ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Third-Party Risk ,
White Collar Crimes
If I ever told you years ago that the 2021 headlines would be dominated by the “supply chain” crisis, you would have immediately questioned my judgment (and perhaps sanity). The current crisis reflects the roller coaster...more
The Credit Suisse case highlights the significant impact that global corruption and fraud can have on developing economies. Mozambique’s economy suffered serious harm from the scheme, which started to unravel when the IMF...more
10/26/2021
/ Bonds ,
Bribery ,
Corruption ,
Credit Suisse ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
IMF ,
Mozambique ,
Offerings ,
Securities Fraud ,
White Collar Crimes
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
9/29/2021
/ Accounting Controls ,
Bribery ,
Compliance ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk ,
White Collar Crimes
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
6/30/2021
/ Brazil ,
Bribery ,
Compliance ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Oil & Gas ,
Petrobras ,
Public Contracts ,
Risk Management ,
Settlement ,
Third-Party Risk ,
White Collar Crimes
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more
6/29/2021
/ Brazil ,
Bribery ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Oil & Gas ,
Petrobras ,
Public Contracts ,
Risk Management ,
Settlement ,
Third-Party Risk ,
White Collar Crimes
Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more
Goldman Sachs has a new leadership role – unfortunately, it is for corruption. It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors. Instead, Goldman...more
Steele Compliance Solutions recently announced the global rollout of its new “Risk Intelligence Data” platform. Companies are suffering from information overload -- with new technologies, companies can manage information to...more