Introduction: A Deal Too Good to Be True When Adani Enterprises Limited (AEL) entered the liquified petroleum gas (LPG) market in 2023, it needed a competitive edge. It found one — a Dubai-based supplier offering meaningfully discounted LPG, purportedly from Oman and Iraq. It was a compelling deal. It was also, as OFAC’s May 18, 2026 enforcement release makes clear, a sanctions disaster hiding in...
If you want to give your compliance team superpowers, then give them the power of automation. If your compliance program is still operating primarily through spreadsheets, emails, and manual tracking, regulators already view your program as ineffective. Modern compliance risks move too fast for manual systems. You need to have sanction screening, third-party monitoring, transaction testing, hotline analytics, policy certifications, and training program metrics. The...
Let me say something that the technology industry does not say loudly enough. Artificial intelligence makes mistakes. Serious ones. And in high-stakes professional environments, those mistakes can cause real harm. Every interaction with Claude or ChatGPT comes with the same quiet disclaimer: “AI can make mistakes.” We have all seen it. Most of us scroll past it. We should not. That disclaimer is not boilerplate....
The Department of Justice (“DOJ”) continues to expand its aggressive health care fraud enforcement efforts with the announcement of a new West Coast Health Care Fraud Strike Force. The initiative reflects DOJ’s ongoing commitment to coordinated, data-driven enforcement targeting fraud schemes involving federal health care programs, telemedicine, kickbacks, billing fraud, and emerging technology-enabled misconduct. The creation of the new Strike Force underscores several important trends:...
Introduction: A Deal Too Good to Be True When Adani Enterprises Limited (AEL) entered the liquified petroleum gas (LPG) market in 2023, it needed a competitive edge. It found one — a Dubai-based supplier offering meaningfully discounted LPG, purportedly from Oman and Iraq. It was a compelling deal. It was also, as OFAC’s May 18, 2026 enforcement release makes clear, a sanctions disaster hiding in...
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...
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 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,...
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...
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...
