Category: General

DOJ’s Balt Case: A Textbook Example of Declination in Exchange for Individual Accountability

For years, the Department of Justice has tried to sharpen a simple message: companies that voluntarily disclose misconduct, cooperate fully, remediate effectively—and identify responsible individuals—can earn significant credit, including declinations. The recent Balt matter is one of the clearest examples yet of that policy in action. On the one hand, DOJ issued a declination to Balt, a medical device company, despite a multi-year bribery scheme...

Proactive Compliance Requires More Than Automation — It Demands AI-Driven Strategy

Proactive Compliance Requires More Than Automation — It Demands AI-Driven Strategy

For years, compliance programs have operated like rearview mirrors. They looked backward, reviewed what already happened, and responded after risks had materialized. That approach is now obsolete. In today’s environment, where regulatory change moves quickly, business operations span multiple jurisdictions, and risk signals emerge from massive volumes of data, reactive compliance is a losing strategy. Companies need compliance programs that can anticipate, prioritize, and respond...

AI Governance: Why Companies Need a Step-by-Step Implementation Strategy

AI Governance: Why Companies Need a Step-by-Step Implementation Strategy

Artificial intelligence is no longer a future concept or a side experiment. It is here, and companies across every sector are racing to deploy AI tools in compliance, legal, finance, HR, procurement, cybersecurity, customer service, and operations. That creates opportunity, but it also creates risk. Too many organizations are approaching AI adoption with a mix of excitement, pressure, and improvisation. That is a mistake. AI...

OFAC’s TradeStation Enforcement Action: A Case Study in “Set It and Forget It” Compliance Failures

OFAC’s TradeStation Enforcement Action: A Case Study in “Set It and Forget It” Compliance Failures

OFAC’s recent enforcement action against TradeStation Securities is a powerful reminder of a basic but often overlooked truth: compliance controls are only as effective as the testing, monitoring, and accountability that support them. The case is not about the absence of a compliance program—it is about the failure to ensure that the program actually worked. According to OFAC, TradeStation was fined approximately $1.1 million for...

What DOJ’s New Corporate Enforcement Policy Means for Compliance Programs (Part II of II)

What DOJ’s New Corporate Enforcement Policy Means for Compliance Programs (Part II of II)

The most important aspect of DOJ’s revised Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy may be its unmistakable message to compliance professionals: a compliance program will be judged not by what it says on paper, but by whether it can drive fast, credible, and measurable action when misconduct is uncovered. This is where the unified policy has real day-to-day significance for companies. For years,...

DOJ’s New Corporate Enforcement Policy: A More Structured Path to Cooperation Credit (Part I of II)

DOJ’s New Corporate Enforcement Policy: A More Structured Path to Cooperation Credit (Part I of II)

The Department of Justice has now unified and revised its approach to corporate enforcement in a way that deserves close attention from corporate boards, general counsel, compliance officers, and white collar defense counsel. With its issuance of the Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy, DOJ has attempted to bring greater transparency and consistency to a subject that has too often depended on discretionary,...

The Challenges of Maintaining Regulatory Compliance

The Challenges of Maintaining Regulatory Compliance

Maintaining regulatory compliance has never been easy. Today, it is becoming even harder. Financial institutions and other regulated businesses are facing a steady wave of new laws, guidance, enforcement priorities, and supervisory expectations. The challenge is no longer limited to digesting a few major rule changes each year. Instead, compliance teams are being forced to manage a continuous stream of smaller, interconnected updates arriving from...

The Continuing Threat of Individual FCPA Enforcement Actions in 2026

The Continuing Threat of Individual FCPA Enforcement Actions in 2026

The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA guidelines. Whether that uptick signals a sustained enforcement trend remains uncertain. The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continue to balance FCPA enforcement against other national priorities, and senior officials have issued at times inconsistent public statements regarding enforcement...

LRN’s 2026 Ethics & Compliance Program Effectiveness Report: Compliance at an Inflection Point

LRN’s 2026 Ethics & Compliance Program Effectiveness Report: Compliance at an Inflection Point

Each year, LRN’s Ethics & Compliance Program Effectiveness Report provides one of the most useful snapshots of the global compliance profession. The 2026 report—“The Next Leap: Technology, Trust, and the Transformation of Compliance”—again offers valuable insight into how corporate ethics and compliance programs are evolving amid rapid technological change, new regulatory expectations, and shifting workplace culture Based on surveys of more than 2,500 compliance professionals...

BIS Fines Navy Contractor for Illegally Sharing Controlled Military Specifications With Chinese Manufacturer

BIS Fines Navy Contractor for Illegally Sharing Controlled Military Specifications With Chinese Manufacturer

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has imposed a $374,474 civil penalty against California-based satellite technology supplier Vizocom for unlawfully exporting controlled technical data related to military antennas to a Chinese manufacturer. Although framed as a single Export Administration Regulations (EAR) violation, the enforcement action carries outsized compliance lessons — particularly for defense contractors navigating cost pressures, supply chain decisions,...