Everyone’s talking about the DOJ going soft on 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 actually went. 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 aggressively against companies for tariff circumvention and customs fraud, with qui tam relators 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: trade, tariffs, sanctions, export controls, and national security.

If your compliance program is still built entirely 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.