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
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