The $275 million OFAC settlement with Adani Enterprises Limited offers a powerful compliance roadmap for multinational companies involved in energy trading, shipping, commodities, logistics, and cross-border finance. The enforcement action demonstrates that sanctions compliance failures often do not arise from intentional misconduct alone. Instead, enforcement increasingly focuses on inadequate diligence, weak escalation procedures, failure to investigate anomalies, and overreliance on formal documentation. Here are the...

What if the C-suite handed you a gold-plated whistle and asked you to blow it? Here’s the uncomfortable truth. Most corporate scandals were discovered by employees long before management ever learned about it or acted. The problem wasn’t a lack of information. It was a culture where people were afraid to speak up. Companies with strong speak up cultures detect misconduct earlier, reduce enforcement risk,...

On May 18, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a massive $275 million settlement with Adani Enterprises Limited (“AEL”) arising from alleged imports of Iranian-origin liquified petroleum gas (“LPG”) disguised as Omani and Iraqi product. The enforcement action is significant for several reasons. First, it underscores OFAC’s continuing emphasis on disrupting Iranian energy exports and the “shadow fleet” infrastructure...

The Department of Justice’s $549.5 million settlement with Perfectus Aluminum reflects a broader transformation underway in federal enforcement strategy: the False Claims Act is rapidly becoming one of DOJ’s most powerful tools for policing international trade misconduct. For years, companies viewed customs compliance primarily through the lens of administrative enforcement by U.S. Customs and Border Protection. That approach has fundamentally changed. Today, tariff evasion, customs...

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:...