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...
Your company has uncovered a massive criminal scheme. You want to get out of it – you serve up the mastermind on a silver platter for the Justice Department prosecutors. You’re working with the Justice Department and you have to deliver to them one key aspect – individuals who were responsible must be held accountable. You conduct a thorough internal investigation and you collect, analyze...
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...
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...
Your company has uncovered a massive criminal scheme. You want to get out of it – you serve up the mastermind on a silver platter for the Justice Department prosecutors. You’re working with the Justice Department and you have to deliver to them one key aspect – individuals who were responsible must be held accountable. You conduct a thorough internal investigation and you collect, analyze...
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...
Your company uncovers a massive criminal scheme. Are you gonna go down with the ship or are you gonna grab onto the lifeboat that the Justice Department has sent your way? The era of big corporate fines is over, and you have to make sure that you get your company through this without a big fine. What do you do? The Justice Department’s corporate enforcement...
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...
So approximately 10-20% of your third parties are going to present serious AI risks. How do you mitigate those risks? Here’s what you do. One, you assess your needs and identify the risk calculation for each of your third parties, and then you seek two fundamental solutions. Two, contractual provisions are critical, and there’s 6 of them that you need. You have to restrict data...
June 9, 2026 12 Noon EST Sign Up Here Third-party risk management programs are facing unprecedented challenges as companies confront heightened sanctions enforcement, corruption risks, geopolitical instability, cybersecurity threats, supply chain disruptions, and increasingly sophisticated intermediary networks. Regulators and enforcement agencies now expect companies to move beyond static due diligence questionnaires and periodic reviews toward more dynamic, data-driven, and continuously monitored third-party risk management frameworks....
In this episode of Corruption, Crime, and Compliance, Michael Volkov interviews Kilby Macfadden, J.D., CCEP, Managing Director and Associate General Counsel at KPMG LLP, where she serves as Head of Investigations overseeing complex ethics, compliance, and enterprise risk matters. Drawing on her extensive experience in government enforcement and corporate compliance, Kilby discusses the growing importance of organizational justice, building employee trust in internal reporting systems, and creating...
