Category: General

5 May, 2025

LRN Issues New Report Highlighting High-Performing Compliance Programs

LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This year’s report is nothing different. In reporting on a survey of 1500 global ethics and compliance professionals, LRN reports on important trends and measurements. This year’s key findings: High-impact programs are more adept at...

General

2 May, 2025

Reviewing the CPB Enforcement Process Under 19 U.S.C. § 1592 (Part II of II)

CPB’s administrative enforcement program is robust and increasing, especially with the importance of trade and tariff enforcement. There are a lot of “ins and outs” (Big Lewbowski Here) to the administrative process which can make it appear overly complex. Case Initiation: CBP initiates investigations from a variety of sources including routine audits, cargo examinations, e-allegations, and referrals. The import process, for obvious reasons, includes a...

General

29 Apr, 2025

Stepping Into the Enforcement Spotlight — Customs and Border Patrol and Import Enforcement (Part I of II)

The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States has pushed global trade as an objective unto itself. The Trump Administration is raising important questions concerning the benefits to U.S. consumers and workers. As part of this new international...

General

29 Apr, 2025

Global Anti-Corruption Efforts and DOJ’s FCPA Pause

The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight. The Justice Department played a critical role in coordinating international efforts and enforcement. in the face of these developments, foreign prosecutors and even the State of California have publicized their intention to increase anti-corruption enforcement. UK-France-Switzerland Taskforce On March 20, 2025, the United Kingdom, France and Switzerland announced...

General

24 Apr, 2025

DSP Compliance: DOJ Sets July 8, 2025 Deadline (Part III of III)

As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and compliance programs. DOJ dropped a comprehensive set of new regulations governing data security and gave companies a 90-day head start — once we get to July 8, 2025, DOJ warned that...

General

22 Apr, 2025

Practical Issues and the New DSP (Part II of III)

Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding. The DSP framework is new, comprehensive and raises significant risks and requires careful design and implementation of effective compliance strategies. Companies will face different risk levels based on their handling of data, specific market practices and security measures. In this post, I will explore some of the interesting...

General

20 Apr, 2025

Episode 365 — Four Sanctions Cases Everyone Should Know

How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their implications for global companies. He discusses four significant cases that underscore the necessity of robust compliance programs, particularly in light of increased DOJ enforcement actions. Through these examples, he breaks down the consequences of...

General

17 Apr, 2025

DOJ Issues Data Security Program Requirements (Part I of III)

Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative and oversight work was bipartisan in that both parties were committed to sensible initiatives needed to be keeping the government operational and effective. Of course, there were partisan issues but at...

General

16 Apr, 2025

Keeping Track of the Trump Administration Tariffs

To keep track of the Trump Administration tariff plans and actions requires vigilance. The difficulty in monitoring daily tariff actions and the impact is a challenge to all trade compliance officers. Here is the best list that we have been tracking since the Trump Administration started to implement tariffs across a wide range of countries and industries. On April 5, 2025, the Trump Administration implemented...

General

15 Apr, 2025

DOJ Adopts Aggressive Stance Against Algorithmic Coordination in Multiplan Antitrust Filing

Recently, the Antitrust Division of the United States Department of Justice submitted a Statement of Interest in In re: Multiplan Health Insurance Provider Litigation, a class action presently pending before the United States District Court for the Northern District of Illinois, to clarify the legal framework governing the use of common pricing algorithms as a potential basis for liability under Section 1 of the Sherman...