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
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
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
1/14/2025
/ Acquisition Agreements ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ports ,
Regulatory Requirements ,
Risk Management ,
Sanction Violations ,
Settlement ,
Shipping
How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant?
In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary...more
Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ...more
1/9/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations
AAR, a provider of aviation products and services, engaged in two separate bribery schemes. State-owned entities and government agencies permeate the aviation industry. As a result, FCPA risks are embedded in direct...more
1/8/2025
/ Anti-Corruption ,
Aviation Industry ,
Bribery ,
Compliance ,
Corporate Fraud ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ...more
What went wrong when McKinsey paid bribes to secure consulting contracts with South Africa's state-owned enterprises?
In this episode, Michael Volkov dives into the December 2024 DOJ settlement with McKinsey & Company,...more
In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and...more
12/20/2024
/ Bribery ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Fraud ,
India ,
Indictments ,
Misleading Statements ,
Public Contracts ,
Solar Energy ,
White Collar Crimes