Category: General

12 Aug, 2025

Liberty Mutual Pays $4.7 Million for FCPA Declination

In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects consistent application of the existing Corporate Enforcement Policy. While DOJ has issued new guidance on FCPA enforcement reflecting its revised priorities, DOJ’s declination does not reference or incorporate any ideas from the guidance. Instead,...

General

6 Aug, 2025

Lessons Learned in the New Aggressive Trade Enforcement Environment: Cadence Ignored Important Red Flags (Part III of III)

Well, we are in a new era — a fundamental change has occurred, long in the making. National security and trade enforcement have coalesced to elevate trade risks — sanctions and export controls violations will be prosecuted aggressively by DOJ with the support and coordination with relevant regulatory agencies — OFAC, BIS, and DTCC. My focus has not been to instill fear and knee-jerk reactions...

General

5 Aug, 2025

Following the Cadence Trade Violation Bouncing Ball a Typical Scheme (Part II of III)

It takes something more than intelligence to act intelligently — Fyodor Dostoevsky Criminals are not as smart as they think they are. There is nothing so unique that elevates a scheme into the ethereal world of brilliance. The schemes get to be “typical” and the means by which they are executed are often fairly obvious. In most white collar cases, criminals are often sociopaths or...

General

5 Aug, 2025

Cadence Design Systems Settles with DOJ and Commerce Department for Export Control Violations and Agrees to Pay $140 Million (Part I of III)

DOJ’s initiation of its aggressive trade enforcement strategy is quickly unfolding — and the new strategy is a real and significant threat to all companies engaged in international trade. We are no longer in the era of FCPA enforcement; we are entering the new world of aggressive trade enforcement which is pinned to national security issues. Few companies have recognized this fundamental shift in DOJ’s...

General

29 Jul, 2025

NAVEX’s 2025 Hotline Benchmark Report

NAVEX dominates the hotline market. Given its global footprint, NAVEX has access to a large database of employee reports. Building on this unique perspective, NAVEX provides an annual report analyzing the employee reporting data and identifying important trends. On June 3, 2025, NAVEX released its 2025 Regional Whistleblowing & Incident Management Benchmark Report. NAVEX analyzed 2.15 million reports — the highest level ever. Its 2024 report...

General

23 Jul, 2025

Entering the Debate: Balancing Risks, Enforcement, Resources and Priorities

The ethics and compliance field has been tested during the transition to the Trump Administration. Some have held on to the mantra — No Change — to respond to the changes in the role of the federal government, enforcement priorities and expectations. Let me offer a little more nuanced response to the current situation. I agree that a company cannot respond to changes in enforcement...

General

22 Jul, 2025

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich, Connecticut—agreed to remit $11,832,136 to resolve its potential civil liability for a staggering 12,367 apparent violations of multiple U.S. sanctions programs. The violations, which spanned from approximately July 15, 2016 through January 31, 2024, implicated...

General

17 Jul, 2025

Landmark Ninth Circuit Ruling Expands Application of False Claims Act to Trade Enforcement (Part II of II)

DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __ (9th Cir. June 23, 2025). The decision clears the way for DOJ to pursue its aggressive strategy to prevent and punish customs evasion misconduct. Island Industries, a competitor, sued Sigma for...

General

16 Jul, 2025

The False Claims Act and Trade Enforcement (Part I of II)

The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new opportunities and risks for companies involved in international trade. DOJ’s intent is clear and companies should be aware of this growing risk area. In May 2025, DOJ designated “trade and...

General

15 Jul, 2025

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a publicly traded designer and supplier of power semiconductors headquartered in Sunnyvale, California. The agency concluded that AOS committed fifteen violations of the Export Administration Regulations (“EAR”) between May and November 2019 by exporting a...

Category: General

Liberty Mutual Pays $4.7 Million for FCPA Declination

Lessons Learned in the New Aggressive Trade Enforcement Environment: Cadence Ignored Important Red Flags (Part III of III)

Following the Cadence Trade Violation Bouncing Ball a Typical Scheme (Part II of III)

Cadence Design Systems Settles with DOJ and Commerce Department for Export Control Violations and Agrees to Pay $140 Million (Part I of III)

NAVEX’s 2025 Hotline Benchmark Report

Entering the Debate: Balancing Risks, Enforcement, Resources and Priorities

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

Landmark Ninth Circuit Ruling Expands Application of False Claims Act to Trade Enforcement (Part II of II)

The False Claims Act and Trade Enforcement (Part I of II)

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

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