Category: General

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If you’ve been reading Corruption, Crime and Compliance for a while, you already know we cover a lot of ground here, enforcement actions, sanctions developments, board governance, AI risk, and everything in between. But if you’re only catching these posts when they cross your feed, you’re missing a lot of the content we put out every week across several different channels. Here’s a quick rundown...

The EU AI Act: The Digital Omnibus, the Current Timeline, and What to Do Now (Part II of II)

The EU AI Act: The Digital Omnibus, the Current Timeline, and What to Do Now (Part II of II)

Part 1 of this series covered where EU AI Act enforcement genuinely stands today: prohibited practices enforceable since February 2025, general-purpose AI obligations running since August 2025, the Commission’s first formal investigations opened in June 2026 into hiring, credit scoring, and student monitoring AI systems, and full enforcement and fining authority active since August 2026. In Part 2, we look at what the Digital Omnibus...

The EU AI Act: Enforcement Is No Longer Theoretical (Part I of II)

The EU AI Act: Enforcement Is No Longer Theoretical (Part I of II)

For years, compliance officers could talk about the EU AI Act as a looming, mostly future obligation, something to plan for rather than something actively enforced. That era is over. As of August 2, 2026, the European Commission, acting through its European AI Office, holds formal investigative and enforcement authority over general-purpose AI model providers and over the Act’s prohibited AI practices, and the agency...

Congress Sends a Major New Russia and Iran Sanctions Bill to the President: What Compliance Teams Need to Know

Congress Sends a Major New Russia and Iran Sanctions Bill to the President: What Compliance Teams Need to Know

The House of Representatives voted 262 to 159 on the night of September 16 to approve a sweeping Russia and Iran sanctions bill, sending it to President Trump for his expected signature. The legislation, renamed the Lindsey O. Graham Sanctioning Russia and Iran Act after the late South Carolina senator who championed it for more than a year before his death in July, cleared the...

Vendor Management and AI Risks: The Clauses to Actually Negotiate (Part II of II)

Vendor Management and AI Risks: The Clauses to Actually Negotiate (Part II of II)

Part 1 of this series explained why AI vendor relationships break the assumptions built into most standard software procurement templates, and where those legacy templates leave organizations exposed: silent or vague data training rights, indemnification that doesn’t reach AI-specific harms, no meaningful audit rights, and liability caps that quietly undercut whatever protections do exist. Part 2 gets specific about what to actually put in the...

Modifying Vendor Contracts for AI Risk (Part I of II)

Modifying Vendor Contracts for AI Risk (Part I of II)

Every organization that’s adopted AI tools over the past few years has also, whether it realized it or not, been signing a new category of vendor contract, one that carries risks your standard software or services agreement template was never built to address. This is Part 1 of a two-part series on modifying vendor contracts to build in real protections against AI risk. Here, we...

Caremark in 2026, Part 2: Boeing Supplies the Counterweight, and the Framework for Compliance Officers

Caremark in 2026, Part 2: Boeing Supplies the Counterweight, and the Framework for Compliance Officers

Part 1 of this series looked at what the Teligent and Regions Financial cases teach about escalation and response under Delaware’s Caremark doctrine. In Part 2, we turn to the most significant recent Caremark development, the 2026 Boeing dismissal, and what the emerging doctrine means in practice for compliance officers building or defending an oversight program. Boeing 2026: The Counterweight to Caremark’s Expansion The most...

Caremark in 2026, Part 1: What Teligent and Regions Financial Teach About Escalation and Response

Caremark in 2026, Part 1: What Teligent and Regions Financial Teach About Escalation and Response

Delaware courts have spent the last several years wrestling with one of the hardest questions in corporate governance law: at what point does a board’s failure to prevent corporate misconduct stop being ordinary bad management and start being an actual breach of the fiduciary duty of loyalty? That question sits at the center of Caremark doctrine, and a run of recent decisions, involving Teligent, Regions...

OFAC’s $1.4 Million Penalty Against a US Consultant: Why “I Just Give Advice” Doesn’t Work as an Iran Sanctions Defense

OFAC’s $1.4 Million Penalty Against a US Consultant: Why “I Just Give Advice” Doesn’t Work as an Iran Sanctions Defense

OFAC fined an unnamed U.S. consultant just over $1.4 million for Iran sanctions violations tied to advisory work provided to a leading Iranian software company, and this case deserves careful attention because it demolishes a defense I still hear surprisingly often: the idea that providing remote advice, strategic guidance, or consulting services to an Iranian business, without physically operating in Iran or directly running the...

Honeywell Aerospace’s $2 Million Cybersecurity Settlement: The False Claims Act Keeps Finding NIST 800-171 Gaps

Honeywell Aerospace’s $2 Million Cybersecurity Settlement: The False Claims Act Keeps Finding NIST 800-171 Gaps

The Justice Department announced a settlement with Honeywell Aerospace requiring the company to pay $2,042,518 to resolve allegations that it violated the False Claims Act by failing to meet cybersecurity requirements built into a Department of Defense contract. This case adds to a growing body of enforcement actions confirming that DOJ’s Civil Cyber-Fraud Initiative is not slowing down, and it’s a useful reminder that cybersecurity...