When it comes to third-party vendors, what you don’t know is hurting you. Third parties rely on AI for customer service, recruiting, compliance screening, marketing, and decision-making. But when a third party uses AI, your organization is on the hook for legal, regulatory, contractual, and reputational risks. Organizations need to understand which third parties use AI, what tools they use, what data is being shared,...
In Part I of this series, we examined the collision between business pressure for AI adoption and the governance gaps that legal and compliance professionals are scrambling to address. The conflict is real, the stakes are high, and both sides of the debate have legitimate grievances. But the framing of this as a conflict between ‘speed’ and ‘safety’ is fundamentally wrong — and that misframing...
There is a collision happening inside boardrooms across corporate America, and it is not being broadcast in any earnings call or regulatory filing. It is playing out in conference rooms and executive Slack channels, in strategy sessions where business unit leaders are demanding faster AI adoption while legal and compliance officers are sounding alarms about governance gaps the organization has not yet filled. Both sides...
Not all sanctions violations are willful. Some companies just don’t know any better. An effective trade compliance program needs three critical elements. First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags. Employee training is critical. OFAC’s compliance framework specifically identifies training as a core...
Bosch agreed to pay more than $43 million in penalties and disgorgement to resolve allegations that it illegally exported products and software to Huawei in violation of U.S. export control laws. The significant enforcement action, announced jointly by the Bureau of Industry and Security (BIS) and the Department of Justice (DOJ), highlights the continuing risks associated with the Foreign Direct Product (FDP) Rule, the consequences...
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has imposed its largest Russia-related monetary penalty to date, fining travel technology company Sabre Global Technologies more than £1 million (approximately $1.3 million) for sanctions violations involving Russia’s Ural Airlines. Beyond the size of the penalty, however, the enforcement action is significant because it represents OFSI’s first sanctions circumvention case and provides a detailed roadmap of...
The Office of the U.S. Trade Representative (USTR) has launched what may be the most sweeping use of Section 301 authority in the history of American trade law. On June 2, 2026, USTR released its report and proposed action in 60 parallel investigations targeting forced labor enforcement failures across virtually every major U.S. trading partner. The proposal—covering economies that account for an estimated 99.4% of...
What separates effective trade compliance programs from ineffective ones? It starts at the top. Good, bad, or ugly, it all trickles down from the top. Here are the five keys to an effective trade compliance program. The first two are building blocks for leadership and due diligence. First, senior executives and boards must actively support trade compliance. Without leadership engagement, compliance programs become check-the-box exercises....
On June 23, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorizing a broad range of transactions ordinarily incident and necessary to the production, sale, delivery, or offloading of Iranian-origin crude oil, petrochemical products, and petroleum products through August 21, 2026. The authorization applies notwithstanding prohibitions imposed under multiple Iran-related sanctions authorities and expressly...
If you read Parts I and II of this series and concluded that the AI governance problem is primarily an internal one — about what your employees do with AI inside your organization — you have only identified half the exposure. The other half lives outside your walls. It lives in your vendors, your service providers, your agents, your supply chain. And for the vast...
