Corruption, Crime & Compliance

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General

17 Jul, 2025

Landmark Ninth Circuit Ruling Expands Application of False Claims Act to Trade Enforcement (Part II of II)

DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __ (9th Cir. June 23, 2025). The decision clears the way for DOJ to pursue its aggressive strategy to prevent and punish customs evasion misconduct. Island Industries, a competitor, sued Sigma for...
General

16 Jul, 2025

The False Claims Act and Trade Enforcement (Part I of II)

The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new opportunities and risks for companies involved in international trade. DOJ’s intent is clear and companies should be aware of this growing risk area. In May 2025, DOJ designated “trade and...
General

15 Jul, 2025

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a publicly traded designer and supplier of power semiconductors headquartered in Sunnyvale, California. The agency concluded that AOS committed fifteen violations of the Export Administration Regulations (“EAR”) between May and November 2019 by exporting a...
Podcasts

14 Jul, 2025

Episode 377 — Refocusing Due Diligence on Cartel and TCOs

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators,...
General

10 Jul, 2025

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and freight forwarding firm headquartered in Delaware, to resolve Key Holding’s potential civil liability for apparent violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. part 515. The apparent...

17 Jul, 2025

Landmark Ninth Circuit Ruling Expands Application of False Claims Act to Trade Enforcement (Part II of II)

DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __ (9th Cir. June 23, 2025). The decision clears the way for DOJ to pursue its aggressive strategy to prevent and punish customs evasion misconduct. Island Industries, a competitor, sued Sigma for...

General

16 Jul, 2025

The False Claims Act and Trade Enforcement (Part I of II)

The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new opportunities and risks for companies involved in international trade. DOJ’s intent is clear and companies should be aware of this growing risk area. In May 2025, DOJ designated “trade and...

General

15 Jul, 2025

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a publicly traded designer and supplier of power semiconductors headquartered in Sunnyvale, California. The agency concluded that AOS committed fifteen violations of the Export Administration Regulations (“EAR”) between May and November 2019 by exporting a...

Podcasts

14 Jul, 2025

Episode 377 — Refocusing Due Diligence on Cartel and TCOs

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators,...

General

10 Jul, 2025

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and freight forwarding firm headquartered in Delaware, to resolve Key Holding’s potential civil liability for apparent violations of the Cuban Assets Control Regulations (“CACR”), 31 C.F.R. part 515. The apparent...

General

9 Jul, 2025

Cartel and TCO Due Diligence and Risk Factors (Part II of II)

Cartels and TCOs have entrenched themselves in legitimate industry sectors. In recent years, cartels and TCOs have adapted to market changes and new technologies. Many cartels and TCOs are disguising their ownership and financial interests through shell companies, sophisticated networks of third parties and legitimate businesses in real estate, construction, mining, agriculture, export/import, casinos, fintech platforms and finance. The Sinola Cartel in Mexico operates in...

General

8 Jul, 2025

Refocusing Due Diligence on Cartel and TCOs (Part I of II)

Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal organizations (“TCOs”) in a company’s supply chain and distribution channel. The Justice Department has adjusted its enforcement priorities to elevate the importance of prosecuting cartels and TCOs. This initiative will involve a two-fold...

Podcasts

7 Jul, 2025

Episode 376 — DOJ’s Unicat Settlement and the Future Look of Trade Enforcement

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies – a case that reflects the U.S. government’s intensifying focus on trade enforcement across sanctions, export controls, and customs. This...

General

30 Jun, 2025

Lessons Learned from the Unicat Settlement (Part III of III)

The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part foundation of seeking a favorable enforcement resolution. Also, it emphasizes the importance of securing disclosure credit with the Justice Department since Unicat’s parent received a declination because of its early disclosure and complete cooperation. In stark contrast, the...

Podcasts

29 Jun, 2025

Episode 375 — Tariff and Sanctions Enforcement

Tariff and trade violations are on DOJ’s radar screen. No question but starting with Customs and Border Patrol we can expect that regulatory investigations and enforcement actions will increase. Along with that — you can bet on this — DOJ’s criminal prosecution of tariff evaders will increase. This is not very surprising — companies have an incentive to circumvent and evade tariffs. Depending on the...