A significant shift in U.S. enforcement policy is underway, and most companies operating in Mexico, Brazil, and elsewhere in Latin America have not yet fully absorbed what it means for them. Over the past year and a half, the government has moved major cartels and organized criminal networks onto the same legal footing as international terrorist organizations. That reclassification is not a symbolic gesture. It...

The guilty plea entered by Estonian national Andrey Shevlyakov is a useful reminder of just how far the Justice Department is willing to reach, geographically and procedurally, to prosecute export control evasion tied to the Russian military. Shevlyakov, who pleaded guilty to conspiracy to commit export violations, has agreed to pay a $1.5 million fine and faces up to 40 years in prison for his...

A clear pattern has emerged in Justice Department corporate enforcement over the past several months, and it is worth compliance officers and general counsel taking notice: companies are being charged far less often, even in cases where prosecutors believed executives or managers were personally involved in the underlying wrongdoing, and that reduced corporate exposure has not been matched by a corresponding increase in individual prosecutions....

In my last post, I made the affirmative case for CCO empowerment — a direct reporting line to the CEO and a dotted line to the audit committee. Today I want to address the disturbing counter-trend: companies moving compliance back under the general counsel, often justified as cost discipline or organizational simplification. Make no mistake about what this movement represents. It is a retreat from...