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...

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...

I am excited to announce the launch of our new YouTube channel — Volkov Law TV. Over the years, through Corruption, Crime & Compliance, Volkov Law webinars, podcast interviews, and speaking engagements, we have worked to provide timely analysis and practical guidance on the rapidly evolving world of corporate compliance, enforcement, sanctions, internal investigations, and corporate risk management. Volkov Law TV is the next step...

In Part I, we outlined how organizational justice aligns with DOJ expectations. The next step is execution—building systems that deliver fairness consistently. Timeliness: A Core DOJ Expectation The DOJ evaluates whether companies investigate misconduct promptly and effectively. Delays raise critical concerns: Companies should establish clear timelines for: Timely investigations are a hallmark of an effective compliance program. Independent Oversight: Ensuring Objectivity The DOJ places significant...

In today’s enforcement environment, the message from the U.S. Department of Justice is clear: culture, internal reporting, and investigative integrity are central to evaluating corporate compliance programs. Under the DOJ’s Evaluation of Corporate Compliance Programs (ECCP), prosecutors are directed to assess whether a company has established a system that encourages employees to report misconduct—and whether the company responds in a fair, consistent, and effective manner....