Featured Articles:

BIS Imposes Suspended $1.7 Million Penalty on Coastal PVA Technology for Unlicensed Exports to Entity List Parties

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement action involving Coastal PVA Technology, Inc., a California-based manufacturer of polyvinyl alcohol (“PVA”) brushes used in semiconductor manufacturing processes. The action arises under the Export Administration Regulations (“EAR”) and follows the issuance of a Proposed Charging Letter alleging multiple violations stemming from exports to restricted parties in...

BIS Imposes Civil Penalty on Thales Defense & Security for Antiboycott Violations

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), through its Office of Antiboycott Compliance, recently issued an Order resolving an administrative enforcement action involving Thales Defense & Security, Inc. arising under the antiboycott provisions of the Export Administration Regulations (“EAR”). The matter stems from conduct occurring in 2019 in connection with a transaction involving the United Arab Emirates and resulted in the...

Episode 405 — DOJ Balt Declination: Individual Accountability in Action

In this episode, we examine the Department of Justice’s declination in the Balt Medical case—a textbook example of how DOJ is applying its Corporate Enforcement Policy in practice. Despite a multi-year foreign bribery scheme involving payments to a physician at a state-owned hospital, DOJ declined to prosecute the company based on its timely self-disclosure, full cooperation, and effective remediation. But the real story lies in...

BIS Imposes $1.6 Million Civil Penalty in Enforcement Action Involving Unlicensed Exports to Entity List Parties

On March 27, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement matter involving Solventum Corporation of St. Paul, Minnesota, arising under the Export Administration Regulations (“EAR”). BIS had previously notified Solventum of its intent to initiate administrative proceedings through the issuance of a Proposed Charging Letter alleging two violations of the Regulations. The matter...

Episode 404 — Venezuela Sanctions Update

In this episode, we break down the sweeping shift in U.S. sanctions policy toward Venezuela following the 2026 political transition and the issuance of multiple new general licenses by the Office of Foreign Assets Control. While the U.S. has opened the door to significant commercial activity—particularly in oil, gas, and minerals—this is not a full lifting of sanctions but a highly conditional framework with strict...

DOJ’s Balt Case: A Textbook Example of Declination in Exchange for Individual Accountability

For years, the Department of Justice has tried to sharpen a simple message: companies that voluntarily disclose misconduct, cooperate fully, remediate effectively—and identify responsible individuals—can earn significant credit, including declinations. The recent Balt matter is one of the clearest examples yet of that policy in action. On the one hand, DOJ issued a declination to Balt, a medical device company, despite a multi-year bribery scheme...

Episode 403 — The Continuing Threat of FCPA Enforcement Against Individuals

The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain. But one theme remains clear: individual FCPA enforcement is alive and well. While corporate resolutions may benefit from evolving DOJ policy and a renewed emphasis on negotiated dispositions, individuals continue to face indictment,...

Proactive Compliance Requires More Than Automation — It Demands AI-Driven Strategy

For years, compliance programs have operated like rearview mirrors. They looked backward, reviewed what already happened, and responded after risks had materialized. That approach is now obsolete. In today’s environment, where regulatory change moves quickly, business operations span multiple jurisdictions, and risk signals emerge from massive volumes of data, reactive compliance is a losing strategy. Companies need compliance programs that can anticipate, prioritize, and respond...

AI Governance: Why Companies Need a Step-by-Step Implementation Strategy

Artificial intelligence is no longer a future concept or a side experiment. It is here, and companies across every sector are racing to deploy AI tools in compliance, legal, finance, HR, procurement, cybersecurity, customer service, and operations. That creates opportunity, but it also creates risk. Too many organizations are approaching AI adoption with a mix of excitement, pressure, and improvisation. That is a mistake. AI...

Episode 402: Paul Allen: The Promise of AI, Governance and Public Trust

In this episode of Corruption, Crime and Compliance, Michael Volkov sits down with entrepreneur and innovator Paul Allen, founder of Ancestry.com and Soar.com, to explore the evolving intersection of artificial intelligence, governance, and public trust. Paul shares insights from his latest venture, CitizenPortal.ai, an AI-powered civic intelligence platform aimed at making government activity more transparent, accessible, and accountable to everyday citizens. The conversation moves beyond hype,...