Episode 366 -- DOJ Issues Data Security Program Requirements
CHPS Podcast Episode 3: Unlocking America's Mineral Potential
No Password Required: SVP at SpyCloud Labs, Former Army Investigator, and Current Breakfast Champion
Sunday Book Review: April 13, 2025, The Books on Trade and Tariffs Edition
Podcast - The "I" in FOCI and AI: Innovation, Intelligence, Influence
Podcast - What Are Joint Ventures and When Should They Get Cleared?
FINCast Ep. 40 – 21st Century Financial Warfare: Technology, Economy, & National Security
All Things Investigations: Terrorism Designations of Mexican Cartels Fundamentally Enhances Risk for All Companies
Podcast - Reflecting on Careers in National Security Law
The Presumption of Innocence Podcast: Episode 54 - The Flaws of FARA: Feeble Oversight of Billions in Foreign Influence
Podcast - Navigating Regulatory Challenges in M&A Transactions
Foreign Correspondent: An FDI Podcast | Mapping the National Security Landscape for Investors
Analyzing the Overlap Between CFIUS and FOCI
A Comprehensive Overview of FOCI Mitigation
Podcast - Defense Dynamics: Navigating the Post-Election Landscape for the National Security Sector, Part 2
AI Post-Election – Initial Government Insights
Mitigating FOCI Under Section 847
Podcast - Staying Compliant When Sharing Employees or Services
Everyone Come to Play: Exploring FOCI Mitigation Instruments
Podcast - FOCI Mitigation: SSAs, SCAs and Proxy Agreements
The recent sentencing of Israeli freight forwarder Gal Haimovich to two years in federal prison for violations of U.S. export controls serves as a striking example of the aggressive enforcement posture adopted by U.S....more
Heightened federal scrutiny of unauthorized technology transfers to foreign entities has once again resulted in high-profile criminal convictions, as two senior executives of Quadrant Magnetics, a Kentucky-based manufacturer...more
Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...more
On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more
On February 5, 2025, in one of her first actions as the nation’s chief law enforcement official, Attorney General Pam Bondi issued several new memoranda that significantly refocus US Department of Justice (DOJ) national...more
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
Sigma-Aldrich, Inc., d/b/a MilliporeSigma (“MilliporeSigma”), a U.S. life sciences company based in Massachusetts, escaped criminal charges for export control violations, despite a former sales person’s scheme to illegally...more
On March 7, 2024, the U.S. Department of Justice’s National Security Division (NSD) issued an updated Enforcement Policy for Business Organizations. The updated policy encourages companies to voluntarily disclose to NSD...more
On March 5, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of Justice (“DOJ”) issued a...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more
The Justice Department has made it clear that it intends to prioritize criminal prosecution of national security cases to prevent hostile nation-states from illegally acquiring sensitive U.S technology. To this end, DOJ...more
The largest criminal monitorship in U.S. history has ended. On March 22, 2022 a U.S. judge ruled that Chinese telecommunications giant ZTE Corporation had completed the terms of its five-year probation, which began in 2017...more
On November 18, 2020, the Department of Justice (DOJ) announced that a Chinese national and naturalized citizen of the United States was sentenced to 38 months in prison for travelling to China with unclassified...more
On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more
Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations. Last year, Quad Graphics earned a declination for FCPA and OFAC violations. In 2013, Weatherford settled...more
In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more
China is in the process of drafting a new comprehensive Export Control Law, following the June 2017 release of an initial draft for comment (Draft Export Control Law) by the Ministry of Commerce of the People’s Republic of...more
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more