Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program. First, content monitoring. The content that you generate through Chat GPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks. When it comes to AI...
The Treasury Department, through a coordinated rulemaking effort involving OFAC and FinCEN, has taken a significant step toward formalizing anti-money laundering and sanctions compliance expectations for a rapidly evolving segment of the financial services industry—permitted payment stablecoin issuers. The recently issued Notice of Proposed Rulemaking reflects a deliberate attempt to bring these entities squarely within the ambit of the Bank Secrecy Act framework, while at...
The Department of Justice’s recent declination in the Balt Medical matter provides another important data point in understanding how DOJ is applying its updated Corporate Enforcement and Voluntary Self-Disclosure Policy in practice. While declinations are always fact-specific, this letter offers a textbook example of how a company can navigate a significant FCPA issue and still avoid criminal prosecution. The declination letter, issued to Balt SAS,...
On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) unveiled a sweeping proposed rule aimed at modernizing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations under the Bank Secrecy Act (BSA). The proposal, developed in coordination with federal banking regulators, reflects a significant evolution in how regulators evaluate compliance programs, enforce obligations, and encourage innovation. At...
Artificial intelligence is rapidly transforming business operations—but it is also introducing a new generation of legal, ethical, and compliance risks. In this episode, we explore how AI risk is accelerating across organizations, from data leakage and bias to over-reliance on flawed outputs and hidden third-party exposure. Drawing on real enforcement trends and practical examples, we explain why AI risk is fundamentally a human and governance...
Here are 3 more reasons you may think twice about letting ChatGPT run your compliance program. First, content monitoring. The content that you generate through Chat GPT or any AI service can raise real risks with regard to improper intellectual property, data privacy risks where you name certain individuals or name certain identifiers, and most importantly, remember your third-party risks. When it comes to AI...
The Treasury Department, through a coordinated rulemaking effort involving OFAC and FinCEN, has taken a significant step toward formalizing anti-money laundering and sanctions compliance expectations for a rapidly evolving segment of the financial services industry—permitted payment stablecoin issuers. The recently issued Notice of Proposed Rulemaking reflects a deliberate attempt to bring these entities squarely within the ambit of the Bank Secrecy Act framework, while at...
The Department of Justice’s recent declination in the Balt Medical matter provides another important data point in understanding how DOJ is applying its updated Corporate Enforcement and Voluntary Self-Disclosure Policy in practice. While declinations are always fact-specific, this letter offers a textbook example of how a company can navigate a significant FCPA issue and still avoid criminal prosecution. The declination letter, issued to Balt SAS,...
On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) unveiled a sweeping proposed rule aimed at modernizing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations under the Bank Secrecy Act (BSA). The proposal, developed in coordination with federal banking regulators, reflects a significant evolution in how regulators evaluate compliance programs, enforce obligations, and encourage innovation. At...
Artificial intelligence is rapidly transforming business operations—but it is also introducing a new generation of legal, ethical, and compliance risks. In this episode, we explore how AI risk is accelerating across organizations, from data leakage and bias to over-reliance on flawed outputs and hidden third-party exposure. Drawing on real enforcement trends and practical examples, we explain why AI risk is fundamentally a human and governance...
Are you actually thinking of turning over your compliance program to ChatGPT? If so, you need to listen to this. AI has to be implemented in a methodical way, a step-by-step program. So let’s talk about those steps. First, you need a governance structure, meaning you have to have an organization responsible across the entire organization for all your uses of AI. Second, like every...
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...
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...
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...
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...
