The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...
Christian Focacci rejoins us for an update on AI technology and risk management developments. Christian is the founder and CEO of Threat.Digital, which leverages large language models and real-time data feeds to empower organizations to identify risk information confidently and efficiently. Mike and Chris discuss latest developments in AI and the relevant compliance issues. Christian can be reached at [email protected]
Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs. Corporate leaders and compliance officials are making a serious mistake when they confuse a “pause” in FCPA enforcement to mean a reduction in federal criminal prosecutions. This Administration has no problem in taking aggressive positions in the legal arena and I would expect...
With each new Administration comes a new approach or emphasis on certain enforcement priorities. The Trump Administration is marking its territory and doing so to underscore its priorities. In a recent speech, the Assistant Attorney General Matthew R. Galeotti for the Criminal Division announced DOJ’s new approach. To reinforce this new approach, DOJ issued a new memorandum, Focus, Fairness and Efficiency in the Fight Against...
With the recent announcement by the Justice Department of a “pause” in FCPE enforcement, questions have arisen as to the U.S. continuing commitment to international anti-corruption efforts and re-focused priorities. To examine the shifting landscape, Michael Volkov invited Scott Greytak, the Director of Advocacy for Transparency International US and Scott Birenbaum, deputy director of FDD’s Center on Economic and Financial Power, to discuss the current...
The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States has pushed global trade as an objective unto itself. The Trump Administration is raising important questions concerning the benefits to U.S. consumers and workers. As part of this new international...
LRN’s Program Effectiveness Report is an important annual event. LRN consistently provides important trend, benchmarking and program measurements. As an important leader in this area, LRN never pulls any punches. This year’s report is nothing different. In reporting on a survey of 1500 global ethics and compliance professionals, LRN reports on important trends and measurements. This year’s key findings:
The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight. The Justice Department played a critical role in coordinating international efforts and enforcement. In the face of these developments, foreign prosecutors and even the State of California have publicized their intention to increase anti-corruption enforcement. In this Episode, Michael Volkov reviews global anti-corruption initiatives and provides updates on...
Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this episode of Corruption, Crime and Compliance, Michael Volkov breaks down the Justice Department’s sweeping new Data Security Program, enacted under Executive Order 14117 and finalized in January 2025....
What do you do when the headlines shift faster than your risk matrix can keep up? In this episode, Michael Volkov dives into the challenge of adapting compliance programs in the face of volatile and fast-changing global risks—from tariffs and trade controls to supply chain disruptions and third-party exposures. While the pressure to react is constant, the real key is staying anchored in your company’s...
