On October 9, 2026, OFAC announced a $175,015 settlement with Pegasus Worldwide Logistics, a California freight forwarder of about a dozen employees. The dollar figure is modest, and the shipment at the center of the case was a machine worth $5,950. But the action is one of the clearest recent illustrations of how an ordinary trade transaction becomes a sanctions violation, and it speaks directly...

Nearly every company has a code of conduct, and nearly every employee has signed off on it. That is the good news in LRN’s 2026 Code of Conduct Report, “The Culture Behind the Code.” The harder news is that the signature may be doing most of the work. The report combines an analysis of more than 1,000 codes with a survey of roughly 2,000 employees...

For decades, the legal test for an anti-money laundering program under the Bank Secrecy Act has been, in practice, a test of completeness. Did the institution have written policies? A designated compliance officer? Independent testing? Training? Examiners checked for the pillars, and an institution with all of them in place could reasonably feel it had met its obligation, even if no one could say whether...

On October 5, the Federal Trade Commission sent warning letters to 24 of the nation’s largest healthcare services companies, telling them that they have a legal obligation to give patients timely, accurate, and complete pricing information, and that failing to do so can be an unfair or deceptive practice under Section 5 of the FTC Act. The agency did not name the recipients. But the...

Companies that sell software often think of an export as a physical event: a box leaves the warehouse. The Commerce Department’s latest settlement with Lambda Research Corporation is a pointed reminder that for software companies, the export may be an automatic update pushed to a customer overseas months or years after the original sale. The Bureau of Industry and Security announced the settlement on Friday,...

On October 1, 2026, Assistant Attorney General Colin McDonald issued Directive 26-12 to all personnel of the Department of Justice’s National Fraud Enforcement Division. The five-page memorandum, titled “Corporate Enforcement in the Fight Against Fraud,” is addressed to prosecutors, but compliance officers and general counsel should read it as if it were addressed to them. It identifies the fraud schemes that will receive priority, lists...