Earlier this year, the Securities and Exchange Commission (SEC) charged Archer-Daniels-Midland Company (ADM) and three of its former executives with accounting and disclosure fraud, in what has become one of the most significant financial reporting enforcement actions of 2026. The case underscores a fundamental compliance truth: strong internal controls and transparent disclosures are not optional — they are core risk mitigants that protect investors, markets, and corporate reputations....

Conflicts of interest are not abstract compliance niceties. They are serious risks to integrity that, if left unidentified or unmitigated, can erode employee trust, compromise decision-making, and expose organizations to regulatory enforcement, litigation, and reputational harm. Recent high-profile scandals involving relationships between supervisors and subordinates have underscored how personal conflicts can quickly morph into enterprise-wide compliance failures when controls, oversight, and ethical culture are weak....

The Justice Department has increased False Claims Act prosecutions, reflecting a continued focus on healthcare fraud and a new initiative on trade fraud.  DOJ announced the largest annual recovery figure in the FCA’s history — $6.8 billion in settlements and recoveries.  FCA whistleblowers filed a record number of new cases — 1,297 lawsuits and the government initiated 401 investigations.  Since 1986, DOJ has recovered a...

The compliance industry appears to be taken over by AI-this and AI-that.  Third party risk bleeds into major AI risks, corporate governance needs to incorporate AI risks, and policies and procedures have to incorporate AI risks, while of course no risk assessment is worth its sale unless there is a discussion of dramatic AI risks. My first response is whoa — let’s all take a...

The most significant compliance and enforcement issue remains trade enforcement — sanctions and export controls.  In the second posting, I want to focus on the new and interesting development in this area: the use of the False Claims Act to capture violations of tariffs and customs duties. With all the hype on the trade compliance front, when you calculate the numbers relating to criminal enforcement,...