Tariff and trade violations are on DOJ’s radar screen. No question but starting with Customs and Border Patrol we can expect that regulatory investigations and enforcement actions will increase. Along with that — you can bet…
more
/ Administrative Law, Criminal Law, International Law & Trade
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of U.S…
more
/ Administrative Law, Finance & Banking, International Law & Trade
Is your company ready to bet its future on whether it can outpace a whistleblower to the DOJ’s door?
In this episode, Michael Volkov takes a deep dive into the Department of Justice’s newly announced strategy to reshape…
more
/ Criminal Law, Energy & Utilities, Finance & Banking, Science, Computers, & Technology, Securities Law
In the prior post, I cited three significant risk areas for False Claims Act (“FCA”) risks and trade compliance: (1) Valuation; (2) Misclassification and (3) Country of Origin. On April 18, 2025, the United States filed a…
more
/ Administrative Law, Civil Remedies, Commercial Law & Contracts, Criminal Law, International Law & Trade
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 power…
more
/ Administrative Law, Criminal Law, International Law & Trade
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 mistake…
more
/ Administrative Law, Commercial Law & Contracts, Criminal Law, Government Contracting, International Law & Trade
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 and…
more
/ Administrative Law, Business Organizations, Commercial Law & Contracts, Criminal Law, International Law & Trade
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
/ Administrative Law, Business Organizations, Commercial Law & Contracts, Criminal Law
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
/ Criminal Law, Mergers & Acquisitions, International Law & Trade, Science, Computers, & Technology, Securities Law
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 Assistant…
more
/ Administrative Law, Business Organizations, Commercial Law & Contracts, Criminal Law
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 Trump…
more
/ Administrative Law, Commercial Law & Contracts, Immigration Law, International Law & Trade, Labor & Employment Law
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
/ Criminal Law, Finance & Banking, International Law & Trade, Science, Computers, & Technology, Securities Law
On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and…
more
/ Business Organizations, Commercial Law & Contracts, Criminal Law, Government Contracting, Labor & Employment Law
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 year’s…
more
/ Business Organizations, Commercial Law & Contracts, Mergers & Acquisitions, Science, Computers, & Technology
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 can…
more
/ Administrative Law, International Law & Trade
