Category: General

How Do Undisclosed Relationships Turn Into Major Corruption Cases?

The biggest cases of corruption and fraud often have their roots in the soil of conflicts of interest. Many major corruption cases begin with something companies initially dismiss as just a conflicts issue. Conflicts of interest though are early warning signs for fraud, bribery, procurement manipulation, favoritism, and self-dealing. Weak disclosure systems allow undisclosed relationships, hidden ownership interests, and vendor manipulation. Effective programs require annual...

FTI Consulting’s $1.05 Million OFAC Settlement: You Cannot Do Indirectly What You Cannot Do Directly

The Office of Foreign Assets Control delivered a pointed lesson in sanctions compliance this week with the announcement of a $1,050,000 settlement with FTI Consulting, Inc., one of the world’s most prominent business advisory firms. The enforcement action involves what might appear at first glance to be a technical violation — unpaid invoices routed through a law firm intermediary. But the compliance lessons embedded in...

Are Your Distributors Getting You Into Sanctions Trouble?

Are you ready to navigate the risky waters of third-party pirates? Most sanctions violations do not happen because companies intentionally want to evade and violate sanctions. They happen because companies trust the wrong third party. The epsilon and elf enforcement matters, which I frequently speak about, demonstrate that companies get in trouble when they have weak distributor oversight, poor intermediary screening, inadequate beneficial ownership review,...

BIS Resolves Antiboycott Enforcement Action Against Colt’s Manufacturing Company

On May 18, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), through its Office of Antiboycott Compliance, issued an Order resolving an antiboycott enforcement matter involving Colt’s Manufacturing Company LLC (“Colt”) arising under the Export Administration Regulations (“EAR”). The matter was resolved through a Settlement Agreement pursuant to which Colt admitted to the conduct described in a Proposed Charging Letter alleging...

EU Export Controls Continue to Evolve Beyond Traditional Dual-Use Frameworks

The European Commission recently published an Information Note concerning measures adopted by Member States under Regulation (EU) 2021/821, the European Union’s framework governing the control of exports, brokering, technical assistance, transit, and transfer of dual-use items. Although administrative in structure, the report provides meaningful insight into the continuing evolution of export controls across the European Union and highlights the increasingly significant role that Member States...

DOJ Indicts Chinese Shipping Container Cartel: A Wake-Up Call for Antitrust Compliance

The Justice Department’s Antitrust Division has struck a major blow against international cartel conduct with a historic superseding indictment charging four of the world’s largest shipping container manufacturers and seven of their senior executives for a multi-year conspiracy to restrict output and fix prices affecting roughly $35 billion in global commerce. The case involves conduct at the heart of America’s COVID-era supply chain crisis. And...

Can U.S. Companies Do Business in Venezuela Again?

Venezuela is a tempting new business arena. Many companies assume that Venezuela remained completely off limits. That is no longer accurate, the compliance risks are actually increasing. OFAC has issued new Venezuela related general licenses in 2026 involving oil and gas, petrochemicals, mining, critical minerals, financial services, and contingent investment negotiations. US companies are cautiously re-entering portions of the Venezuelan market under these specific licensing...

European Union Gives Final Approval to Landmark Anti-Corruption Directive

The European Union has taken a historic step in the global fight against corruption. The Council of the European Union formally adopted the EU’s first comprehensive Anti-Corruption Directive, creating a harmonized framework for corruption offenses, corporate liability, sanctions, enforcement cooperation, and prevention measures across all EU Member States. For multinational companies, compliance officers, boards of directors, and legal professionals, the Directive represents a major expansion...

Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy

Federal prosecutors and regulators are sending an unmistakable message to the rapidly growing prediction markets industry: insider trading, market manipulation, and misuse of confidential information will not be tolerated simply because trading occurs on decentralized or event-based platforms. The recent insider trading charges involving individuals connected to prediction market trading activity underscore a broader and increasingly coordinated enforcement strategy by the Department of Justice (“DOJ”)...

Does Your Speak-Up Culture Actually Work? (Part 2)

What if you worked at a company where whistleblowers were rewarded? An internal investigation is often the result of a whistleblower concern. And this is the most important test of a company’s ethics and compliance program because employees watch exactly how leadership responds when misconduct surfaces. Poor internal investigations destroy trust through delays, inconsistent discipline, retaliation, and lack of transparency. Effective investigations require independence, speed,...