Author: Michael Volkov

5 Aug, 2025

Cadence Design Systems Settles with DOJ and Commerce Department for Export Control Violations and Agrees to Pay $140 Million (Part I of III)

DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA enforcement; we are entering the new world of aggressive trade enforcement which is pinned to national security issues. Few companies have recognized this fundamental shift in DOJ’s...

Podcasts

3 Aug, 2025

Episode 380 — NAVEX’s 2025 Hotline Benchmark Report

NAVEX dominates the hotline market. Given its global footprint, NAVEX has access to a large database of employee reports. Building on this unique perspective, NAVEX provides an annual report analyzing the employee reporting data and identifying important trends. On June 3, 2025, NAVEX released its 2025 Regional Whistleblowing & Incident Management Benchmark Report. NAVEX analyzed 2.15 million reports — the highest level ever. Its 2024 report...

General

29 Jul, 2025

NAVEX’s 2025 Hotline Benchmark Report

Podcasts

28 Jul, 2025

Episode 379 — Update on False Claims Act and Customs Fraud

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

23 Jul, 2025

Entering the Debate: Balancing Risks, Enforcement, Resources and Priorities

The ethics and compliance field has been tested during the transition to the Trump Administration. Some have held on to the mantra — No Change — to respond to the changes in the role of the federal government, enforcement priorities and expectations. Let me offer a little more nuanced response to the current situation. I agree that a company cannot respond to changes in enforcement...

Podcasts

21 Jul, 2025

Episode 378 — Update on Export and Sanctions Enforcement Cases

The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry and Security imposed significant penalties for violations. BIS Case 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...

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)

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

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...