The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry and Security imposed significant penalties for violations. BIS Case On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor...

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators,...

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies – a case that reflects the U.S. government’s intensifying focus on trade enforcement across sanctions, export controls, and customs. This...

Tariff and trade violations are on DOJ’s radar screen.  No question but starting with Customs and Border Patrol we can expect that regulatory investigations and enforcement actions will increase.  Along with that — you can bet on this — DOJ’s criminal prosecution of tariff evaders will increase.  This is not very surprising — companies have an incentive to circumvent and evade tariffs.  Depending on the...

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 chris@threat.digital

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...