The State Department’s Directorate of Defense Trade Controls just handed down a $36 million penalty against BAE Systems, Inc., resolving more than 100 alleged violations of the International Traffic in Arms Regulations and the Arms Export Control Act stretching from 2019 through as recently as March 2025. This is Part 1 of a two-part series on the case. Here, we walk through the settlement structure...

In this episode of Corruption, Crime and Compliance, Michael Volkov examines L3Harris Technologies’ abrupt ouster of chairman and CEO Christopher Kubasik over a code-of-conduct violation, and why the story is really a board governance cautionary tale rather than a typical enforcement matter. He traces Kubasik’s earlier, similar departure from Lockheed Martin in 2012 alongside comparable cases involving Brian Krzanich at Intel and Mark Hurd at...

Is your routine payment actually a bribe? Scolar, an Omaha agricultural company, resolved an FCPA case for over $10 million after using customs brokers to bribe Mexican officials, about $2,000 for each train that crossed the border. It was invoiced as reinspection fees paid routinely for six years. Nobody asked what the money actually bought. Stop treating customs brokers, freight forwarders, and logistics providers like...

OFAC’s settlement with Rice Lake Weighing Systems is a small-dollar case, just $60,764, but it is an unusually instructive one, because it captures almost every classic failure mode in how U.S. companies manage sanctions compliance at their foreign subsidiaries: a license that got revoked, an instruction that didn’t translate into real understanding, and a subsidiary that kept dealing with a sanctioned country indirectly after being...

The Justice Department rarely hands compliance officers a document that spells out its enforcement priorities this directly, but that’s essentially what Assistant Attorney General Colin McDonald did this week in a memo to staff of the newly formed National Fraud Enforcement Division. The memo is worth reading in full, because it functions less like an internal org chart announcement and more like a public roadmap...

In this episode of Corruption, Crime and Compliance, Michael Volkov makes the case that every organization needs a written AI Acceptable Use Policy now, not eventually, because employees are already using AI tools with or without formal governance. He walks through the three core risk categories driving that urgency: confidentiality exposure when employees submit sensitive data to ungoverned tools, hallucination risk from AI-generated content that...

Veloxis Pharmaceuticals, the maker of the kidney transplant immunosuppression drug Envarsus XR, has agreed to pay more than $46 million and submit to years of enhanced compliance oversight to resolve civil and criminal allegations that the company ran a sustained kickback scheme to drive prescriptions of its drug. This case is worth a close read for compliance officers well beyond the pharmaceutical industry, because it’s...

Have you heard about the Goldman Sachs banker who bribed his way to a conviction? A federal jury in Brooklyn last week convicted Asante Berko, a former Goldman Sachs executive, on FCPA conspiracy, a substantive FCPA violation, and money laundering conspiracy. Berko managed a deal between a Turkish energy company and the government of Ghana to build a new power plant in Ghana. To win...

The Treasury Department rolled out a significant escalation of its Iran sanctions program on August 24, and this one is worth immediate attention from any organization with even indirect exposure to Iran-related activity, because it combines two things that don’t usually arrive together: a large batch of new designations and a suspension of general licenses that companies may have been relying on for years to...

BIS just settled with Container Manufacturing, an Ohio-based maker of tops for aluminum beverage cans, for $1 million over ten violations of U.S. export controls tied to Russia. On the surface, this looks like a modest regional manufacturer case involving unglamorous industrial spare parts. Underneath, it’s one of the clearest illustrations I’ve seen this year of a principle every compliance officer needs to internalize: a...