The Justice Department knows how to use the False Claims Act — it is the primary tool against fraudsters in the healthcare industry, and going back even further, it was used against the defense industry in the 1980s and 1990s. DOJ has turned the tool towards another angle and this portends a significant trend. DOJ is opening up a new front in the trade enforcement...
Typically, I enjoy the New Year (notwithstanding Larry David’s rule of no New Year wishes past 15 days of the New Year). It is important to look back, assess and identify trends; after all, what better marker than annual reviews. The most significant compliance and enforcement issue remains trade enforcement — sanctions and export controls. In the second posting, I want to focus on the...
On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Order resolving an administrative enforcement action against Exyte Management GmbH, a Germany-based company headquartered in Stuttgart, in connection with alleged violations of the Export Administration Regulations (“EAR”). The action arose from conduct occurring between March 2021 and March 2022 and involved in-country transfers of items subject to the...
Welcome to 2026, a 10/1 year in numerology (if you are into it). Wherever you might be on the political spectrum, we can all agree that there is a lot happening, and there has been some significant changes. While I occasionally hear about the impact of our social climate on corporate ethics and compliance, let me offer a positive perspective that confirms the continuing —...
I was grateful to appear on Umbereen Ahmed’s new podcast, CEO Tech Talks. Umbereen and I had a great discussion on the importance of ethics and compliance, the direct financial benefit and the need for a robust compliance program to mitigate AI risks. Here is the LINK TO THE EPISODE.
Happy New Year! We hope everyone had a wonderful and restful holiday. With the New Year, we wanted to rejoin the blogosphere. the podcast community and our webinar audience. We are still in the process of re-designing the Volkov Law website and were hoping to complete that process by January 1, 2026. However, given delays and pressing assignments, we were unable to meet the optimistic...
On September 30, 2025, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, announced an administrative settlement with Hallewell Ventures, Ltd. (“Hallewell”) and its beneficial owner, Russian businessman Albert Avdolyan, arising from an unauthorized reexport of a Bombardier Global 7500 aircraft to Russia in March 2022. The matter concludes with a $374,474 civil penalty, payable within thirty days of the order, and conditions...
I have written extensively on the importance of trade compliance. The risk landscape has changed rapidly with the Russia-Ukraine war, the Trump Administration’s focus on tariffs, economic nationalism, and sanctions and export control enforcement. Along with these significant trends, companies have increased focus on supply chain risks and management. A new report from the World Economic Forum (WEF) and PWC, Trade Compliance for Leadership, presents...
You can always count on LRN as a consistent source of important ethics and compliance program trends and insights. In its latest report, LRN provided important insights on company Codes of Conduct. The last report from LRN on this topic was in 2023. LRN’s Report included a comprehensive review of nearly 200 global Codes and a new survey from over 2,000 employees across 15 countries. ...
On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List restrictions to cover affiliates of listed parties. Effective on the date of filing for public inspection, the IFR abandons the longstanding “legally distinct” standard, under which only entities expressly enumerated on the Entity...
