If you’re looking at the Justice Department and only at FCPA cases, you’re looking in the wrong place.

Everyone’s talking about the DOJ going soft on corporate crime. I want to push back on that narrative because I think it’s incomplete and, honestly, a little dangerous if compliance officers believe it.

Yes, traditional FCPA and bribery prosecutions have slowed. But look at where the resources are actually going.

Trade enforcement is exploding. Sanctions enforcement is aggressive and getting more aggressive by the month.

And here’s the one that should really get your attention: the False Claims Act is now being used against companies for tariff circumvention and customs fraud, with qui tam relators and lawyers lining up to bring those cases.

This isn’t a retreat. It’s a reallocation.

DOJ has simply moved its firepower to where the current priorities sit: national security, trade, tariffs, sanctions, and export controls.

If your compliance program is still built around FCPA risk and you haven’t retooled for trade and sanctions exposure, you are exposed right now, today.

Update your risk assessment. This is not the moment to stand down.

The Ethics and Compliance Q and A show is produced by One Stone Creative.