How do you manage risk when the vulnerabilities are outside your organization aren’t in your hands?
In this episode of Corruption, Crime, and Compliance, we delve into the world of third-party risk management with our...more
This week, we bring you a replay of one of our most impactful podcasts from last year, featuring Alex Cotoia and Daniela Melendez. Listen in as we discuss the EU Whistleblower Directive of October 2019. We'll return next week...more
Is your company prepared for the compliance storm ahead?
With tariffs shaking global trade, aggressive sanctions enforcement, and new risks from AI, businesses must rethink their strategies. Can your compliance program keep...more
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
The scope of new import tariffs and regulations portends significant operational risks and disruptions. It is easy to imagine numerous companies that depend on imports for production purposes are facing a new set of...more
2/20/2025
/ Anti-Dumping Duty ,
Canada ,
China ,
Compliance ,
Customs and Border Protection ,
Exports ,
Imports ,
Mexico ,
Regulatory Reform ,
Risk Management ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
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
Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with OFAC for $1.07 million for 73 violations of the Russia Sanctions program. In a separate criminal case, Roman Sinyavsky...more
2/5/2025
/ Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Fines ,
Fraud ,
Guilty Pleas ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
White Collar Crimes
The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact?
While its potential is undeniable, the road...more
When evaluating AI risks, legal, ethics and compliance professionals need to divide the question into two — first, what are risks from legal, ethics and compliance internal use of AI? and second, what are business risks from...more
1/31/2025
/ Artificial Intelligence ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Ethics ,
Intellectual Property Protection ,
Policies and Procedures ,
Risk Management ,
Risk Mitigation
Not to sound like a broken record — but we are consistently asking the compliance community the same question. As far back as March 2013, on this very blog, I wrote a posting — The Future of Compliance — What Will the New...more
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
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
1/24/2025
/ Civil Monetary Penalty ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Sanction Violations ,
US Trade Policies ,
Voluntary Disclosure
OFAC means what it says — in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more
1/23/2025
/ Anti-Corruption ,
Blocked Person ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
Global Magnitsky Act ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Sanctions ,
SDN List ,
Settlement ,
Statutory Violations ,
U.S. Treasury ,
White Collar Crimes
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