As in every Administration, the Trump Department of Justice has made clear its enforcement priorities — government fraud, immigration and national security to include tariff and trade violations. DOJ fully recognizes the...more
Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs. Corporate leaders and compliance officials are making a serious...more
DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process. DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more
5/21/2025
/ Corporate Governance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Crimes ,
Tariffs ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
For years, companies have dreaded DOJ’s potential appointment of a corporate monitorship as part of a criminal resolution. Companies have often complained about the experience, citing burdensome and sometimes unnecessary...more
What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of...more
With each new Administration comes a new approach or emphasis on certain enforcement priorities. The Trump Administration is marking its territory and doing so to underscore its priorities. In a recent speech, the...more
5/15/2025
/ Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
New Guidance ,
Regulatory Reform ,
Trump Administration ,
White Collar Crimes
Call me an optimist — it is a much better alternative than being a pessimist or a “realist” with a pessimistic bent. So, let’s start by acknowledging the obvious. Businesses are operating in a volatile environment. The...more
Are you running a compliance program that’s making a real impact—or just checking the boxes?
In this episode, Michael Volkov dives into LRN’s 2025 Program Effectiveness Report, an annual benchmark that separates the truly...more
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
CPB’s administrative enforcement program is robust and increasing, especially with the importance of trade and tariff enforcement. There are a lot of “ins and outs” (Big Lewbowski Here) to the administrative process which...more
The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States...more
4/30/2025
/ Anti-Dumping Duty ,
Countervailing Duties ,
Customs and Border Protection ,
Enforcement Actions ,
Fraud ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
International Trade ,
Penalties ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
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
To keep track of the Trump Administration tariff plans and actions requires vigilance. The difficulty in monitoring daily tariff actions and the impact is a challenge to all trade compliance officers. Here is the best list...more
4/17/2025
/ Canada ,
Imports ,
International Trade ,
Mexico ,
Retaliatory Tariffs ,
Section 232 ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global...more
Legal and compliance officers are used to adjustments and continuous improvement of their compliance programs. Building and maintaining an effective ethics and compliance program never ends — it is a continuous process. To...more
For compliance officers, this is a stressful time. How is that for another profound grasp of the obvious? Most compliance officers face a well-known assortment of risks — bribery, trade, False Claims Act, data privacy,...more
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
Trade compliance officers are scrambling — they knew change was afoot but no one expected the speed and wide scope of upheaval in the trade arena. One day presents potential changes with serious ramifications....more