Recent enforcement actions by the SEC have reinforced a message that boards and senior leadership have heard before—but too often underestimate in practice: financial reporting risk is a governance risk. When internal controls fail, disclosure judgments are compromised, or performance pressures override discipline, regulators do not view the breakdown as a technical accounting issue. They view it as an oversight failure. The lessons from recent...

In late 2025, the Securities and Exchange Commission (SEC) charged Archer-Daniels-Midland Company (ADM) and three of its former executives with accounting and disclosure fraud, in what has become one of the most significant financial reporting enforcement actions of 2026. The case underscores a fundamental compliance truth: strong internal controls and transparent disclosures are not optional — they are core risk controls that protect investors, markets,...

A real estate executive reached a $3.77 million settlement with the Office of Foreign Assets Control after OFAC accused them of violating U.S. sanctions against Syria. The person — who committed the alleged violations years before the U.S. repealed a host of Syria restrictions in 2025 — provided “managerial services” in their position as a senior official and board member of four Syrian real estate...

The Treasury Department’s Office of Foreign Assets Control (OFAC) has delivered a pointed reminder that sanctions risk is not confined to banks, multinational manufacturers, or energy traders. It extends to schools — even elite athletic boarding schools operating primarily within the United States. In a recent enforcement action, OFAC imposed a civil penalty against IMG Academy, a Florida-based athletic preparatory boarding school, after the school...

For boards and audit committees, culture should be viewed not as an abstract value but as a core internal control—often the most effective one. Traditional controls are necessary but limited. Policies cannot anticipate every scenario. Monitoring systems detect only what they are designed to see. Audits are retrospective. Culture, by contrast, governs behavior when controls are weakest: in gray areas, under pressure, and in decentralized...

Ethics and integrity are often framed as compliance values—important, necessary, but ultimately subordinate to financial performance. That framing misunderstands the role culture plays in sustainable value creation. A strong culture of ethics and integrity is not a cost center or a regulatory hedge; it is a strategic asset that directly influences long-term financial performance, risk stability, and organizational resilience. Organizations with well-developed ethical cultures benefit...

The Commerce Department’s Bureau of Industry and Security (BIS) has sent an unmistakable message to the semiconductor industry: creative interpretations of the Export Administration Regulations (EAR) will not shield companies from significant enforcement risk. Recently. BIS imposed a $252 million penalty against Applied Materials — the second-largest fine in the agency’s history — for illegally exporting semiconductor manufacturing equipment to China’s Semiconductor Manufacturing International Corp....

FINRA’s recent $10 million enforcement action against First Trust Portfolios L.P. sends a clear and unmistakable message to financial services firms: hospitality and gifts remain a high-risk compliance area, particularly when they are excessive, repetitive, poorly tracked, or—most critically—linked to sales performance. The case reflects FINRA’s renewed focus on non-cash compensation practices and demonstrates how seemingly routine entertainment can evolve into a systemic compliance failure...

The most dangerous compliance mistake in 2025 is assuming that fewer enforcement actions mean less exposure. FCPA risk is driven by business operations and control weaknesses, not enforcement statistics. The 2025 enforcement landscape underscores why compliance programs must remain vigilant—even in a slower year. Third parties remain the dominant risk Agents, distributors, consultants, and local intermediaries continue to generate the majority of FCPA exposure. Declinations...

FCPA enforcement in 2025 was defined by what did not happen as much as what did. Compared to prior years, the number of publicly announced cases declined sharply, corporate resolutions were fewer, and the overall enforcement posture appeared more restrained. This slowdown, however, reflects a policy recalibration—not a dismantling—of the FCPA enforcement regime. Early in the year, DOJ paused FCPA enforcement activity while it reviewed...