Category: General

DOJ Indicts Chinese Shipping Container Cartel: A Wake-Up Call for Antitrust Compliance

DOJ Indicts Chinese Shipping Container Cartel: A Wake-Up Call for Antitrust Compliance

The Justice Department’s Antitrust Division has struck a major blow against international cartel conduct with a historic superseding indictment charging four of the world’s largest shipping container manufacturers and seven of their senior executives for a multi-year conspiracy to restrict output and fix prices affecting roughly $35 billion in global commerce. The case involves conduct at the heart of America’s COVID-era supply chain crisis. And...

Can U.S. Companies Do Business in Venezuela Again?

Can U.S. Companies Do Business in Venezuela Again?

Venezuela is a tempting new business arena. Many companies assume that Venezuela remained completely off limits. That is no longer accurate, the compliance risks are actually increasing. OFAC has issued new Venezuela related general licenses in 2026 involving oil and gas, petrochemicals, mining, critical minerals, financial services, and contingent investment negotiations. US companies are cautiously re-entering portions of the Venezuelan market under these specific licensing...

European Union Gives Final Approval to Landmark Anti-Corruption Directive

European Union Gives Final Approval to Landmark Anti-Corruption Directive

The European Union has taken a historic step in the global fight against corruption. The Council of the European Union formally adopted the EU’s first comprehensive Anti-Corruption Directive, creating a harmonized framework for corruption offenses, corporate liability, sanctions, enforcement cooperation, and prevention measures across all EU Member States. For multinational companies, compliance officers, boards of directors, and legal professionals, the Directive represents a major expansion...

Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy

Polymarket Insider Trading Charges Illustrate DOJ and CFTC Prediction Markets Enforcement Strategy

Federal prosecutors and regulators are sending an unmistakable message to the rapidly growing prediction markets industry: insider trading, market manipulation, and misuse of confidential information will not be tolerated simply because trading occurs on decentralized or event-based platforms. The recent insider trading charges involving individuals connected to prediction market trading activity underscore a broader and increasingly coordinated enforcement strategy by the Department of Justice (“DOJ”)...

Does Your Speak-Up Culture Actually Work? (Part 2)

Does Your Speak-Up Culture Actually Work? (Part 2)

What if you worked at a company where whistleblowers were rewarded? An internal investigation is often the result of a whistleblower concern. And this is the most important test of a company’s ethics and compliance program because employees watch exactly how leadership responds when misconduct surfaces. Poor internal investigations destroy trust through delays, inconsistent discipline, retaliation, and lack of transparency. Effective investigations require independence, speed,...

Lessons Learned from the Adani Enterprises OFAC Settlement

Lessons Learned from the Adani Enterprises OFAC Settlement

The $275 million OFAC settlement with Adani Enterprises Limited offers a powerful compliance roadmap for multinational companies involved in energy trading, shipping, commodities, logistics, and cross-border finance. The enforcement action demonstrates that sanctions compliance failures often do not arise from intentional misconduct alone. Instead, enforcement increasingly focuses on inadequate diligence, weak escalation procedures, failure to investigate anomalies, and overreliance on formal documentation. Here are the...

Does Your Speak-Up Culture Actually Work? (Part 1)

Does Your Speak-Up Culture Actually Work? (Part 1)

What if the C-suite handed you a gold-plated whistle and asked you to blow it? Here’s the uncomfortable truth. Most corporate scandals were discovered by employees long before management ever learned about it or acted. The problem wasn’t a lack of information. It was a culture where people were afraid to speak up. Companies with strong speak up cultures detect misconduct earlier, reduce enforcement risk,...

OFAC’s $275 Million Settlement with Adani Enterprises Signals Aggressive Focus on Iranian Energy Evasion

OFAC’s $275 Million Settlement with Adani Enterprises Signals Aggressive Focus on Iranian Energy Evasion

On May 18, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a massive $275 million settlement with Adani Enterprises Limited (“AEL”) arising from alleged imports of Iranian-origin liquified petroleum gas (“LPG”) disguised as Omani and Iraqi product. The enforcement action is significant for several reasons. First, it underscores OFAC’s continuing emphasis on disrupting Iranian energy exports and the “shadow fleet” infrastructure...

The New Era of Trade Enforcement: DOJ’s Expanding Use of the False Claims Act (Part II of II)

The New Era of Trade Enforcement: DOJ’s Expanding Use of the False Claims Act (Part II of II)

The Department of Justice’s $549.5 million settlement with Perfectus Aluminum reflects a broader transformation underway in federal enforcement strategy: the False Claims Act is rapidly becoming one of DOJ’s most powerful tools for policing international trade misconduct. For years, companies viewed customs compliance primarily through the lens of administrative enforcement by U.S. Customs and Border Protection. That approach has fundamentally changed. Today, tariff evasion, customs...

DOJ’s $550 Million False Claims Act Settlement Signals Escalating Tariff Enforcement Risks (Part I of II)

DOJ’s $550 Million False Claims Act Settlement Signals Escalating Tariff Enforcement Risks (Part I of II)

The U.S. Department of Justice’s May 12, 2026 $549.5 million False Claims Act settlement with California-based Perfectus Aluminum represents one of the largest trade-related FCA recoveries in recent years and underscores a critical compliance message for importers, manufacturers, distributors, and global supply chain companies: tariff circumvention has become a major DOJ enforcement priority. According to DOJ allegations, Perfectus Aluminum and affiliated companies evaded antidumping and...