What if you worked at a company where whistleblowers were rewarded? An internal investigation is often the result of a whistleblower concern. And this is the most important test of a company’s ethics and compliance program because employees watch exactly how leadership responds when misconduct surfaces. Poor internal investigations destroy trust through delays, inconsistent discipline, retaliation, and lack of transparency. Effective investigations require independence, speed,...

The Justice Department unsealed a historic superseding indictment charging four of the world’s largest shipping container manufacturers — CIMC, Singamas, Dong Fang, and CXIC — and seven senior executives for conspiring to restrict global container output and fix prices from November 2019 through at least January 2024, covering an estimated $35 billion in commerce and generating near-hundredfold profit increases during the COVID pandemic. In this...

The $275 million OFAC settlement with Adani Enterprises Limited offers a powerful compliance roadmap for multinational companies involved in energy trading, shipping, commodities, logistics, and cross-border finance. The enforcement action demonstrates that sanctions compliance failures often do not arise from intentional misconduct alone. Instead, enforcement increasingly focuses on inadequate diligence, weak escalation procedures, failure to investigate anomalies, and overreliance on formal documentation. Here are the...

The Department of Justice’s $549.5 million False Claims Act settlement with Perfectus Aluminum marks one of the largest customs fraud recoveries in recent years and signals an aggressive new era of tariff enforcement. In this episode, Michael Volkov examines DOJ’s expanding use of the False Claims Act to pursue alleged tariff circumvention schemes, the growing role of whistleblowers in customs enforcement, and the increasing overlap...

What if the C-suite handed you a gold-plated whistle and asked you to blow it? Here’s the uncomfortable truth. Most corporate scandals were discovered by employees long before management ever learned about it or acted. The problem wasn’t a lack of information. It was a culture where people were afraid to speak up. Companies with strong speak up cultures detect misconduct earlier, reduce enforcement risk,...

On May 18, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a massive $275 million settlement with Adani Enterprises Limited (“AEL”) arising from alleged imports of Iranian-origin liquified petroleum gas (“LPG”) disguised as Omani and Iraqi product. The enforcement action is significant for several reasons. First, it underscores OFAC’s continuing emphasis on disrupting Iranian energy exports and the “shadow fleet” infrastructure...

Your company has uncovered a massive criminal scheme. You want to get out of it – you serve up the mastermind on a silver platter for the Justice Department prosecutors. You’re working with the Justice Department and you have to deliver to them one key aspect – individuals who were responsible must be held accountable. You conduct a thorough internal investigation and you collect, analyze...

The Department of Justice’s $549.5 million settlement with Perfectus Aluminum reflects a broader transformation underway in federal enforcement strategy: the False Claims Act is rapidly becoming one of DOJ’s most powerful tools for policing international trade misconduct. For years, companies viewed customs compliance primarily through the lens of administrative enforcement by U.S. Customs and Border Protection. That approach has fundamentally changed. Today, tariff evasion, customs...

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...

Your company uncovers a massive criminal scheme. Are you gonna go down with the ship or are you gonna grab onto the lifeboat that the Justice Department has sent your way? The era of big corporate fines is over, and you have to make sure that you get your company through this without a big fine. What do you do? The Justice Department’s corporate enforcement...