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...

The regulatory and compliance tensions between the United States and China continue to intensify as Beijing expands its legal framework for countering foreign sanctions, export controls, and other forms of what it characterizes as improper extraterritorial jurisdiction. Recent Chinese measures, including the Regulations on Countering Improper Extraterritorial Jurisdiction by Foreign States and the State Council’s Provisions on Industrial and Supply Chain Security, reflect a broader...

I am excited to announce the launch of our new YouTube channel — Volkov Law TV. Over the years, through Corruption, Crime & Compliance, Volkov Law webinars, podcast interviews, and speaking engagements, we have worked to provide timely analysis and practical guidance on the rapidly evolving world of corporate compliance, enforcement, sanctions, internal investigations, and corporate risk management. Volkov Law TV is the next step...

In Part I, we outlined how organizational justice aligns with DOJ expectations. The next step is execution—building systems that deliver fairness consistently. Timeliness: A Core DOJ Expectation The DOJ evaluates whether companies investigate misconduct promptly and effectively. Delays raise critical concerns: Companies should establish clear timelines for: Timely investigations are a hallmark of an effective compliance program. Independent Oversight: Ensuring Objectivity The DOJ places significant...

In today’s enforcement environment, the message from the U.S. Department of Justice is clear: culture, internal reporting, and investigative integrity are central to evaluating corporate compliance programs. Under the DOJ’s Evaluation of Corporate Compliance Programs (ECCP), prosecutors are directed to assess whether a company has established a system that encourages employees to report misconduct—and whether the company responds in a fair, consistent, and effective manner....

On May 1, 2026, Donald Trump signed a new executive order significantly expanding U.S. sanctions targeting Cuba. The order reflects a renewed effort to tighten economic pressure on the Cuban government by broadening the scope of sanctionable conduct, increasing exposure for foreign financial institutions, and targeting corruption and human rights abuses more directly. For companies with even indirect connections to Cuba, the message is clear:...

Recent enforcement actions by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) highlight a clear and consistent message for companies engaged in global trade: export control compliance programs are no longer optional—they are foundational risk management requirements. Three recent cases—two involving unlicensed exports to Entity List parties and one addressing antiboycott violations—underscore the breadth of BIS enforcement priorities and the recurring compliance...

As organizations rapidly adopt artificial intelligence, many are overlooking a critical exposure point: third-party AI risk. Companies are not just deploying AI internally—they are increasingly relying on vendors, platforms, and service providers that embed AI into their offerings. From SaaS providers using generative AI to analytics vendors deploying machine learning models, AI risk is now embedded across the third-party ecosystem. This creates a fundamental shift...

The U.S. State Department’s Directorate of Defense Trade Controls (DDTC) recently imposed a $36 million penalty on General Electric (GE) for widespread violations of the International Traffic in Arms Regulations (ITAR). The enforcement action highlights persistent compliance failures across multiple dimensions — including technical data exports, licensing errors, and internal control breakdowns — and serves as a critical reminder of the risks companies face in...

As companies accelerate adoption of artificial intelligence tools across business functions, one reality is becoming increasingly clear: AI risk is not theoretical—it is operational, immediate, and enterprise-wide. From generative AI tools used in marketing and legal functions to machine learning embedded in products and decision-making systems, organizations face a rapidly evolving risk landscape that cuts across privacy, cybersecurity, intellectual property, employment law, and regulatory compliance....