We live in a topsy-turvy world.  This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has to take a hard look at your company’s risks and reassess and re-rank them. Initial Review Some basic business and technology risks will stay the...

The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer.  When cooler heads prevail, it is much easier to pick through the relevant issues and prioritize the issues and analysis. First, we need to put this in perspective.  From a much larger viewpoint, the FCPA pause has to be considered...

As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling.  In some respects, we have had a preview.  It is hard to know what will happen beyond some basic points. Let’s start with last week’s memo issued by Attorney General Bondi, which was entitled — Total Elimination of Cartels and...

What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump Administration during the first term had an aggressive record of FCPA enforcement. We all expected that to continue. Boardrooms, C-Suites and Legal/Compliance professionals are stunned.  How...

In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice.  The White House’s announcement seemed to take everyone by “surprise” but in the end was “expected” in light of recent announcements coming from Attorney General Bondi. The President’s Executive Order In an Executive Order that appeared...

In an unprecedented and surprising set of actions, the new Attorney General Bondi issued eleven new, internal directives for the Department of Justice.  The new Directives are available HERE. Immediately after her confirmation and swearing in, AG Bondi issued 14 separate directives that hit the Justice Department with significant changes in policy and priorities.  Eliminating Internal Discriminatory Practices: Following President Trump’s Executive Order, Ending Illegal...

Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with  OFAC for $1.07 million for 73 violations of the Russia Sanctions program.  In a separate criminal case, Roman Sinyavsky pleaded guilty to circumventing U.S. sanctions and money laundering.  Between 2018 and 2023, and 2023, Family International and Sinyavsky transferred nominal ownership of three luxury condominiums owned by two sanctioned Russian...

In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical control (“CNC”) machines, for dozens of violations of the Export Administration Regulations (“EAR”). The enforcement action stems from allegations that Haas facilitated the unauthorized export, reexport, or transfer of U.S.-origin machine...

The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact? While its potential is undeniable, the road ahead is full of risks, challenges, and ethical concerns. Will AI drive efficiency and innovation, or will it create new vulnerabilities that companies must scramble to control? In...

When evaluating AI risks, legal, ethics and compliance professionals need to divide the question into two — first, what are risks from legal, ethics and compliance internal use of AI? and second, what are business risks from employing AI capabilities in specific functions and use cases? Sometimes ethics and compliance professionals are surprised to learn that certain functions — finance, security, HR or others —...