The $275 million OFAC settlement with Adani Enterprises Limited offers a powerful compliance roadmap for multinational companies involved in energy trading, shipping, commodities, logistics, and cross-border finance. The enforcement action demonstrates that sanctions compliance failures often do not arise from intentional misconduct alone. Instead, enforcement increasingly focuses on inadequate diligence, weak escalation procedures, failure to investigate anomalies, and overreliance on formal documentation. Here are the...

What if the C-suite handed you a gold-plated whistle and asked you to blow it? Here’s the uncomfortable truth. Most corporate scandals were discovered by employees long before management ever learned about it or acted. The problem wasn’t a lack of information. It was a culture where people were afraid to speak up. Companies with strong speak up cultures detect misconduct earlier, reduce enforcement risk,...

On May 18, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a massive $275 million settlement with Adani Enterprises Limited (“AEL”) arising from alleged imports of Iranian-origin liquified petroleum gas (“LPG”) disguised as Omani and Iraqi product. The enforcement action is significant for several reasons. First, it underscores OFAC’s continuing emphasis on disrupting Iranian energy exports and the “shadow fleet” infrastructure...

The Department of Justice’s $549.5 million settlement with Perfectus Aluminum reflects a broader transformation underway in federal enforcement strategy: the False Claims Act is rapidly becoming one of DOJ’s most powerful tools for policing international trade misconduct. For years, companies viewed customs compliance primarily through the lens of administrative enforcement by U.S. Customs and Border Protection. That approach has fundamentally changed. Today, tariff evasion, customs...

The U.S. Department of Justice’s May 12, 2026 $549.5 million False Claims Act settlement with California-based Perfectus Aluminum represents one of the largest trade-related FCA recoveries in recent years and underscores a critical compliance message for importers, manufacturers, distributors, and global supply chain companies: tariff circumvention has become a major DOJ enforcement priority. According to DOJ allegations, Perfectus Aluminum and affiliated companies evaded antidumping and...

The regulatory and compliance tensions between the United States and China continue to intensify as Beijing expands its legal framework for countering foreign sanctions, export controls, and other forms of what it characterizes as improper extraterritorial jurisdiction. Recent Chinese measures, including the Regulations on Countering Improper Extraterritorial Jurisdiction by Foreign States and the State Council’s Provisions on Industrial and Supply Chain Security, reflect a broader...