Corruption, Crime & Compliance

Featured Articles:

General

8 Oct, 2025

BIS Imposes $374,474 Civil Penalty on Hallewell Ventures and Albert Avdolyan for Unlicensed Reexport of Bombardier Aircraft to Russia

On September 30, 2025, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, announced an administrative settlement with Hallewell Ventures, Ltd. (“Hallewell”) and its beneficial owner, Russian businessman Albert Avdolyan, arising from an unauthorized reexport of a Bombardier Global 7500 aircraft to Russia in March 2022. The matter concludes with a $374,474 civil penalty, payable within thirty days of the order, and conditions...
General

5 Oct, 2025

World Economic Forum: Trade Compliance for Leadership

I have written extensively on the importance of trade compliance. The risk landscape has changed rapidly with the Russia-Ukraine war, the Trump Administration’s focus on tariffs, economic nationalism, and sanctions and export control enforcement. Along with these significant trends, companies have increased focus on supply chain risks and management. A new report from the World Economic Forum (WEF) and PWC, Trade Compliance for Leadership, presents...
General

2 Oct, 2025

LRN Report on Code of Conduct Trends

You can always count on LRN as a consistent source of important ethics and compliance program trends and insights. In its latest report, LRN provided important insights on company Codes of Conduct. The last report from LRN on this topic was in 2023. LRN’s Report included a comprehensive review of nearly 200 global Codes and a new survey from over 2,000 employees across 15 countries. ...
General

1 Oct, 2025

BIS Expands Entity List Controls to Cover Affiliates of Listed Parties

On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List restrictions to cover affiliates of listed parties. Effective on the date of filing for public inspection, the IFR abandons the longstanding “legally distinct” standard, under which only entities expressly enumerated on the Entity...
General

29 Sep, 2025

NAVEX State of Risk and Compliance Report

Like the annual Presidential State of the Union Address, NAVEX’s yearly State of Risk and Compliance Report provides important insights and benchmarks against which compliance professionals can measure their own accomplishments and upcoming priorities. This year, NAVEX surveyed nearly 1000 risk and compliance professionals. The headline findings are fascinating and impportant to consider. The New Priority of Artificial Intelligence (AI) We are all aware of...

8 Oct, 2025

BIS Imposes $374,474 Civil Penalty on Hallewell Ventures and Albert Avdolyan for Unlicensed Reexport of Bombardier Aircraft to Russia

On September 30, 2025, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, announced an administrative settlement with Hallewell Ventures, Ltd. (“Hallewell”) and its beneficial owner, Russian businessman Albert Avdolyan, arising from an unauthorized reexport of a Bombardier Global 7500 aircraft to Russia in March 2022. The matter concludes with a $374,474 civil penalty, payable within thirty days of the order, and conditions...

General

5 Oct, 2025

World Economic Forum: Trade Compliance for Leadership

I have written extensively on the importance of trade compliance. The risk landscape has changed rapidly with the Russia-Ukraine war, the Trump Administration’s focus on tariffs, economic nationalism, and sanctions and export control enforcement. Along with these significant trends, companies have increased focus on supply chain risks and management. A new report from the World Economic Forum (WEF) and PWC, Trade Compliance for Leadership, presents...

General

2 Oct, 2025

LRN Report on Code of Conduct Trends

You can always count on LRN as a consistent source of important ethics and compliance program trends and insights. In its latest report, LRN provided important insights on company Codes of Conduct. The last report from LRN on this topic was in 2023. LRN’s Report included a comprehensive review of nearly 200 global Codes and a new survey from over 2,000 employees across 15 countries. ...

General

1 Oct, 2025

BIS Expands Entity List Controls to Cover Affiliates of Listed Parties

On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List restrictions to cover affiliates of listed parties. Effective on the date of filing for public inspection, the IFR abandons the longstanding “legally distinct” standard, under which only entities expressly enumerated on the Entity...

General

29 Sep, 2025

NAVEX State of Risk and Compliance Report

Like the annual Presidential State of the Union Address, NAVEX’s yearly State of Risk and Compliance Report provides important insights and benchmarks against which compliance professionals can measure their own accomplishments and upcoming priorities. This year, NAVEX surveyed nearly 1000 risk and compliance professionals. The headline findings are fascinating and impportant to consider. The New Priority of Artificial Intelligence (AI) We are all aware of...

General

23 Sep, 2025

OFAC Penalizes ShapeShift AG $750,000 for Apparent Sanctions Violations

On September 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the resolution of an enforcement action against ShapeShift AG (“ShapeShift”), a now defunct digital asset exchange incorporated in Switzerland but headquartered and operated from Denver, Colorado. ShapeShift agreed to remit $750,000 to settle its potential civil liability for apparent violations of multiple U.S. sanctions programs, including those directed...

General

22 Sep, 2025

EU Clarifies Ownership and Control Standards in New Sanctions Guidance

The European Union has continued to refine its approach to sanctions compliance by publishing new guidance on the critical issues of “ownership” and “control” through its Sanctions Helpdesk platform. The guidance—released in late August 2025—offers much-needed clarity on how companies operating within the Union should identify, evaluate, and manage the risks posed by indirect links to sanctioned parties. In particular, the document provides detailed direction...

General

17 Sep, 2025

The Ever-Evolving Framework for Third-Party Risk Management

Compliance has its lingo — and one particular one I like, Third-Party Risk Management or “TPRM.” Years ago, everyone cited third-party risks. Now, we use TPRM as if everyone knows exactly what it stands for. The language usually evolves with the substance. And that is certainly true. The coverage of third-party risk has expanded with the years to embrace many new risks, issues and challenges....

Events

15 Sep, 2025

Webinar: DOJ Pushes Aggressive Trade Enforcement Strategy

Webinar: DOJ Pushes Aggressive Trade Enforcement Strategy October 21, 2025, 12 Noon Sign-Up HERE The Trump Administration has warned that DOJ and regulatory agencies (OFAC, BIS and DDTC) intend to seek stiff punishment for violations of tariffs, sanctions and export controls. DOJ’s new initiative has been unveiled in two significant enforcement actions — Cadence Design Systems and Unicat Catalyst — where DOJ organized a comprehensive...

General

11 Sep, 2025

DOJ Settles Two False Claims Act Cases for Evasion of Customs Duties

The Trump Justice Department has fully embraced the False Claims Act, stretching its use to include trade enforcement. DOJ recognizes the power of the FCA, the issues at stake, and the ability to extract large settlements. DOJ has used the FCA to capture companies that evade customs duties. DOJ’s recent actions are a reminder for import companies to carefully scrutinize valuation and customs duties to...