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...
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...
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...
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...
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...
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...
Legal and compliance officers are used to adjustments and continuous improvement of their compliance programs. Building and maintaining an effective ethics and compliance program never ends — it is a continuous process. To this end, in the environment of rapid change, compliance officers know how to remain steady and focus on emerging risks. The strategies are often similar but the substance differs when new threats...
For compliance officers, this is a stressful time. How is that for another profound grasp of the obvious? Most compliance officers face a well-known assortment of risks — bribery, trade, False Claims Act, data privacy, cybersecurity and conflicts of interest. Risks would move up or down depending on trends or specific industry operations. Further, with rapid technological change, new risks emerged such as artificial intelligence...
The Trump Administration is focused on change in the government’s role, the administrative state, and the political environment. With these changes, you can expect the Trump Administration to aggressively pursue violators — DOJ is being re-organized in a way to decentralize prosecutorial discretion to the U.S. Attorneys’ Offices among the 94 specific judicial districts. DOJ’s supervisory role had been a hinderance in certain areas, and...
Chief compliance officers are adjusting a new, risk world, where top risks include export controls, sanctions, and immigration enforcement. At the same time, some risks remain — third-party risks, conflict of interest, fair competition, and yes, even anti-bribery. At the beginning of a new Administration, there is a lag between intentions and actions. It takes time to move the government enforcement and regulatory machinery and...
