Corruption, Crime & Compliance

Featured Articles:

General

27 Jun, 2025

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration. DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to prosecute the parent company that voluntarily disclosed the violations quickly after acquiring Catalyst. As detailed in court documents and in DOJ’s agreements with White Deer and Unicat, from approximately 2014 through 2021, Mani...
General

26 Jun, 2025

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A Context (Part I of III)

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies (“Unicat”), under which Unicat agreed to pay forfeiture totaling $3,325,052.10, representing the proceeds of its violations of U.S. sanctions, export control and customs laws. In parallel resolutions coordinated between the Justice Department, the OFAC and...
Events

24 Jun, 2025

Webinar: DOJ’s New FCPA Enforcement and Compliance Strategy

July 22, 2025, 12 PM EST Sign Up HERE After a pause in enforcement, DOJ issued its new FCPA enforcement and compliance strategy. DOJ’s strategy is new and contains important statements re enforcement priorities. At the same time, DOJ’s strategy includes elements that are consistent with prior policies and guidance. DOJ’s continued focus on individual prosecutions is nothing new, but the new focus on national...
General

24 Jun, 2025

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a priority for this Administration. As expected, the Justice Department will play a more evident role in the sanctions enforcement process. This a new development, when DOJ declines there may be disclosure of...
Podcasts

22 Jun, 2025

Episode 374 — DOJ Resumes FCPA Enforcement

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...

27 Jun, 2025

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration. DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to prosecute the parent company that voluntarily disclosed the violations quickly after acquiring Catalyst. As detailed in court documents and in DOJ’s agreements with White Deer and Unicat, from approximately 2014 through 2021, Mani...

General

26 Jun, 2025

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A Context (Part I of III)

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies (“Unicat”), under which Unicat agreed to pay forfeiture totaling $3,325,052.10, representing the proceeds of its violations of U.S. sanctions, export control and customs laws. In parallel resolutions coordinated between the Justice Department, the OFAC and...

Events

24 Jun, 2025

Webinar: DOJ’s New FCPA Enforcement and Compliance Strategy

July 22, 2025, 12 PM EST Sign Up HERE After a pause in enforcement, DOJ issued its new FCPA enforcement and compliance strategy. DOJ’s strategy is new and contains important statements re enforcement priorities. At the same time, DOJ’s strategy includes elements that are consistent with prior policies and guidance. DOJ’s continued focus on individual prosecutions is nothing new, but the new focus on national...

General

24 Jun, 2025

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a priority for this Administration. As expected, the Justice Department will play a more evident role in the sanctions enforcement process. This a new development, when DOJ declines there may be disclosure of...

Podcasts

22 Jun, 2025

Episode 374 — DOJ Resumes FCPA Enforcement

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...

General

17 Jun, 2025

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change. Here is my list of what’s new and what’s the same. 1. Increased individual prosecutions and reduced emphasis on corporate prosecutions: The DOJ FCPA Guidance Memo prioritizes individual prosecutions and avoidance...

General

16 Jun, 2025

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

Podcasts

15 Jun, 2025

Episode 373 — Christian Focacci on AI Trends and Risk Management

Christian Focacci rejoins us for an update on AI technology and risk management developments. Christian is the founder and CEO of Threat.Digital, which leverages large language models and real-time data feeds to empower organizations to identify risk information confidently and efficiently. Mike and Chris discuss latest developments in AI and the relevant compliance issues. Christian can be reached at [email protected]

General

12 Jun, 2025

Supreme Court’s Wire Fraud Decision Raises Risks for Government Contractors

In a unanimous decision, the U.S. Supreme Court, in Kousisis v. United States affirmed a lower court’s decision upholding a conviction of federal wire fraud for inducing a victim to enter into a transaction under materially false pretenses, even if the defendant did not intend to cause the victim economic loss. The Supreme Court rejected the limiting of federal fraud cases to those where there...

General

11 Jun, 2025

Understanding Section 301 and 232 Tariffs

With the rising importance of trade compliance programs, it is important to start with the law. (Spoken like a true lawyer). The U.S. relies on two powerful tariff tools — Section 301 and Section 232 tariffs. Relying on these provisions, the U.S. government can impose additional duties on imported goods. The key difference between the two is the specific legal authority and the different policy...

Featured Articles:

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A Context (Part I of III)

Webinar: DOJ’s New FCPA Enforcement and Compliance Strategy

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

Episode 374 — DOJ Resumes FCPA Enforcement

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A Context (Part I of III)

Webinar: DOJ’s New FCPA Enforcement and Compliance Strategy

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

Episode 374 — DOJ Resumes FCPA Enforcement

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

Episode 373 — Christian Focacci on AI Trends and Risk Management

Supreme Court’s Wire Fraud Decision Raises Risks for Government Contractors

Understanding Section 301 and 232 Tariffs

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